Defendant was the sole occupant of his hotel room, and the absent renter consented to the search. That consent was binding on defendant under Randolph. It wasn’t ineffective assistance of counsel for defense counsel to fail to argue for an extension of Randolph that likely wouldn’t go anywhere. Also, he could have objected and didn’t. Officers did nothing to prohibit it. Rasberry v. United States, 2019 U.S. Dist. LEXIS 62339 (D. Me. Apr. 11, 2019).
After a misdemeanor trial, defendant claimed the police did an illegal plain view resulting in some of the evidence against him. That’s waived. United States v. Pinchotti, 2019 U.S. Dist. LEXIS 61508 (D. Md. Apr. 10, 2019).*
Defendant didn’t sufficiently make a claim of a Franks violation, and there was a basis for finding of probable cause. United States v. Alexandre, 2019 U.S. Dist. LEXIS 61409 (D. Me. Apr. 10, 2019).*