N.D.Ill.: Moving place of search of belongings away from alley where def was arrested to inside wasn’t unreasonable

Officers had a warrant for defendant’s person and belongings. It wasn’t unreasonable to move the place of the search from the alley where he was arrested inside, even as a search incident. United States v. Sanchez, 2019 U.S. Dist. LEXIS 118539 (N.D. Ill. July 17, 2019).

The trial court didn’t err in denying a Franks motion without a hearing because there was no substantial preliminary showing of falsity or materiality. People v. Alize, 2019 NY Slip Op 05676, 2019 N.Y. App. Div. LEXIS 5657 (2d Dept. July 17, 2019).*

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