NC: Car parked on street was not on the curtilage

A car parked on the street next to a house was not on the curtilage as a matter of law. Based on undisputed facts in the record, however, the officer had probable cause to search the car on the street. State v. Degraphenreed, 2018 N.C. App. LEXIS 859 (Sep. 4, 2018).

Defense counsel wasn’t ineffective for not filing a motion to suppress of a search warrant based on a controlled buy that was recorded and that couldn’t possibly succeed. State v. Silcott, 2018-Ohio-3507, 2018 Ohio App. LEXIS 3809 (2d Dist. Aug. 31, 2018).*

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