Plain view during a probation “compliance check” is valid. State v. Cheramie, 2019 La. App. LEXIS 576 (La. App. 1 Cir. Apr. 5, 2019).
Defense counsel filed a motion to suppress which was heard and denied. He then pled guilty. Then he filed a 2255 petition claiming defense counsel didn’t properly handle the suppression issue. No prejudice shown; denied. Hernandez-Sanchez v. United States, 2019 U.S. Dist. LEXIS 59424 (W.D. Wash. Apr. 5, 2019).*