Officers went to defendant’s home for a knock-and-talk and could smell green marijuana. Their second attempt at a knock-and-talk wasn’t unreasonable under Jardines. United States v. White, 2019 U.S. App. LEXIS 19446 (8th Cir. June 28, 2019).
“Ferguson, however, does not describe with any specificity the purportedly false statements, much less substantiate the information by the sworn statements of witnesses. … Nor does Ferguson explain how the false information would negate the finding of probable cause. This dooms Ferguson’s request for an evidentiary hearing under Franks on the basis of false statements, as ‘conclusory allegations of deliberately or recklessly false information’ do not entitle a defendant to a Franks hearing.” United States v. Ferguson, 2019 U.S. Dist. LEXIS 109028 (N.D. Ind. June 27, 2019).*