No IAC for not moving to suppress where there’s no standing

Defense counsel wasn’t ineffective for not pursuing a motion to suppress that the co-defendant already lost on the merits and for which defendant had no standing. State v. Adkins, 2019 Del. Super. LEXIS 335 (July 16, 2019).*

Defense counsel wasn’t ineffective for not moving to suppress this search of another’s hotel room because it’s apparent defendant had no standing. People v. Byrd, 2019 NY Slip Op 05721, 2019 N.Y. App. Div. LEXIS 5741 (3d Dept. July 18, 2019).*

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