Defendant was an anti-abortion protestor with a sound system, and he was detained for a noise violation after officers with a 3M sound meter found him over the sound ordinance limit. He was to be arrested for that and he resisted. He raised on appeal that his arrest was unlawful; so therefore his arrest for resisting arrest was unlawful. He didn’t raise that in the trial court and can’t on appeal. State v. Pavkovic, 2019 N.C. App. LEXIS 761 (Sept. 17, 2019).
Petitioner’s proffer does not show an egregious violation of the Fourth Amendment to allow the exclusionary rule to apply to immigration searches. Euceda v. Barr, 2019 U.S. App. LEXIS 27822 (9th Cir. Sept. 16, 2019).*