The affidavit for a search warrant based in part on a dog sniff doesn’t have to also justify the dog’s training to show probable cause. Failure to provide it isn’t a Franks violation. United States v. Tullous, 2019 U.S. Dist. LEXIS 158266 (W.D. Tenn. July 25, 2019), adopted, 2019 U.S. Dist. LEXIS 156746 (W.D. Tenn. Sept. 13, 2019).
Playpen warrant sustained. The circuit has already ruled on that issue. United States v. Caswell, 2019 U.S. App. LEXIS 27910 (11th Cir. Sept. 17, 2019).*
2255 petitioner’s claim that his supervised release arrest warrant wasn’t supported by probable cause is denied, and a certificate of appealability is denied. United States v. Palacio, 2019 U.S. App. LEXIS 27913 (5th Cir. Aug. 13, 2019).*