The CI had knowledge defendant was going to commit a robbery and was enlisted to rent a car for it. The CI told the police, and they planted a GPS on the car with the CI’s permission. After the robbery, defendant was stopped. The trial court held he lacked standing in the rented car, but that was before Byrd. That was error, but harmless and moot. The stop was based on probable cause. Strong v. State, 2019 Fla. App. LEXIS 15316 (Fla. 5th DCA Oct. 11, 2019).
Defendant’s motion to suppress was denied and appealed. “Movant’s attempt here to raise the same issue again under the guise of ineffective assistance of counsel is unavailing.” All he said was that defense counsel was ineffective without saying what he should have done that would have changed the outcome. Durham v. United States, 2019 U.S. Dist. LEXIS 176421 (S.D. Fla. Oct. 9, 2019).*