Defense counsel wasn’t ineffective for not moving to suppress the search of a cigarette pack removed from defendant’s person at the time of his arrest but searched 30 minutes later. It was still subject to the search incident doctrine. Greene v. State, 2019 Mo. LEXIS 316 (Sept. 3, 2019).
There was probable cause to arrest defendant as he attempted to enter the crime scene of a murder after he was identified by witnesses as the shooter. State v. Watison, 2019 Tenn. Crim. App. LEXIS 552 (Aug. 30, 2019).*
There was probable cause for issuance of the arrest and search warrant. There was no Franks violation. The witnesses at first didn’t fully corroborate their final statement but they finally said it was because they were scared. Thus, it wasn’t material or would change the outcome to have included that. Jackson v. State, 2019 Ga. LEXIS 599 (Sept. 3, 2019).