CA2: Nonmaterial error of fact in Title III application and SW for house didn’t merit Franks hearing

Nonmaterial error in inclusion of an erroneous fact in a wiretap application and search request for house didn’t require a Franks hearing. United States v. Osborne, 2018 U.S. App. LEXIS 17142 (2d Cir. June 25, 2018).*

Defendant’s post-conviction claim defense counsel didn’t file a motion to suppress was wrong because the lawyer did. It wasn’t meritorious and was (apparently) part of the Anders brief defense counsel filed. State v. Wilson, 2018 Del. Super. LEXIS 265 (June 19, 2018).*

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