“It was reasonable and prudent for Magistrate Judge Brown to issue the search warrant based upon Agent Daniel’s affidavit because that affidavit established at least a ‘fair probability’ that tattoos evidencing affiliation with the Gangster Disciples would be found on Burks’ body.” United States v. Darden, 2019 U.S. Dist. LEXIS 20897 (M.D. Tenn. Feb. 8, 2019).
Defense counsel did not perform deficiently by failing to pursue a wholly unwinnable suppression argument. State v. Ramey, 2019-Ohio-398, 2019 Ohio App. LEXIS 417 (2d Dist. Feb. 8, 2019).*