Defendant’s consent was voluntary on the totality. “There is no evidence that the detectives coerced the defendant into signing the consent form and the defendant offered no evidence to the trial court that conflicted with Lombardi’s testimony regarding the facts and circumstances surrounding the defendant’s ultimate decision to consent to a search of his person. Thus, his request to consult an attorney does not weigh against a finding of a voluntary consent.” State v. Sachdev, 2018 N.H. LEXIS 229 (Nov. 29, 2018).
Defendant’s guilty plea waived his Fourth Amendment claim, and it wasn’t brought as an ineffective assistance of counsel claim. United States v. Wilkens, 2018 U.S. Dist. LEXIS 202105 (E.D. Pa. Nov. 29, 2018).*