Failure to properly knock-and-announce is foreclosed as a reason for exclusion under Hudson v. Michigan. United States v. Calligan, 2018 U.S. Dist. LEXIS 173193 (N.D. Ind. Oct. 9, 2018).
2255 petitioner was not prejudiced by defense counsel’s failure to challenge the apparent omission of Attachment B to the search warrant when the USMJ issued it. In the overall scheme and conduct of the search, this was mere negligence at worst and not a reason to exclude, and it does not amount to prejudice because the oversearch, if any, was minimal and had no effect on the verdict. United States v. Graves, 2018 U.S. App. LEXIS 28424 (3d Cir. Oct. 9, 2018).*