Defendant called 911 about a prowler possibly inside, and he consented at least implicitly if not explicitly to entry of the responding officer and his dog which then alerted to drugs. The entry was reasonable and consensual. United States v. Iverson, 2018 U.S. App. LEXIS 21121 (2d Cir. July 31, 2018).
Defendant raised and lost his FISA warrant issues in the district court before the conviction, and he can’t raise them on post-conviction. Subasic v. United States, 2018 U.S. Dist. LEXIS 127764 (E.D. N.C. July 31, 2018).*