Defendant’s statement at the side of the road was taken in violation of Miranda and should have been suppressed. This does not affect, however, the Fourth Amendment analysis of whether there was probable cause because there was without the statement. State v. Regelman, 2018 Kan. LEXIS 591 (Dec. 7, 2018).
Franks applies to wiretaps, and defendant fails to even mention what the false statements were here for his offer of proof. United States v. Hinojosa, 2018 U.S. Dist. LEXIS 206798 (N.D. Tex. Dec. 7, 2018).*