Defendant and his girlfriend shared a closet where they were staying, and she had apparent authority to consent to a search of the whole closet, not just her side of it. United States v. Lawson, 2018 U.S. Dist. LEXIS 137966 (D. Me. Aug. 15, 2018).
The area behind defendant’s and other houses was open fields, and the police could search there. Defense counsel couldn’t be ineffective for not raising this in a motion to suppress. McDonald v. United States, 2018 U.S. Dist. LEXIS 136474 (S.D. Ga. Aug. 13, 2018).*
Motion to reconsider denial of a suppression motion is denied because it’s just a rearguing of what happened before. United States v. Salaam, 2018 U.S. Dist. LEXIS 137970 (S.D. Ohio Aug. 15, 2018).*