NE: A pre-Birchfield warrantless blood draw would not be excluded under GFE

A blood draw that predated Birchfield was valid under the good faith exception. “Because the good faith exception applies, the district court erred in reversing Hatfield’s conviction.” State v. Hatfield, 300 Neb. 152 (June 8, 2018).

Two controlled buys by the CI was probable cause. In a search warrant for drugs, looking in a backpack was a reasonable place to search. A gun found there wouldn’t be suppressed. Omission of a detail of a 2014 prior drug deal wasn’t material for Franks purposes. United States v. Norris, 2018 U.S. Dist. LEXIS 96458 (D. Mass. June 8, 2018).*

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