Defense counsel couldn’t be ineffective for not challenging the search of defendant’s apartment because there was probable cause. Sexually explicit Facebook chats with a minor from one’s home IP address is probable cause for the home. United States v. Ram, 2018 U.S. Dist. LEXIS 138457 (W.D.Ark. Aug. 16, 2018).
Officers had an arrest warrant for defendant, and then got consent to enter the place where he was found. Plain view supported the seizures in the house. United States v. Stanton, 2018 U.S. App. LEXIS 22764 (3d Cir. Aug. 16, 2018).*