The government had an objective good faith belief that the defendant in jail consented to a search of a storage unit through his lawyer. The lawyer was asked about whether the officers could have consent or get a search warrant, and defendant told the lawyer either was fine. His motion to reopen a year later to attempt to impeach his lawyer on the exact date of the communication was neither new evidence nor material. United States v. Rodriguez, 2019 U.S. Dist. LEXIS 91996 (S.D. Fla. June 3, 2019).
Plaintiff couldn’t file a § 1983 action over the search of a car he didn’t have standing in. Cruse v. Blackburn, 2019 U.S. Dist. LEXIS 92152 (S.D. W.Va. June 3, 2019).