CA6: One prior excessive force claim isn’t pattern and practice in a § 1983 case

One other excessive force claim investigated by the City is not evidence of pattern and practice or failure to train. Stewart v. City of Memphis, 2019 U.S. App. LEXIS 30491 (6th Cir. Oct. 11, 2019).*

Defendant’s successor 2255 also raises a Fourth Amendment illegal arrest claim that the district court had no jurisdiction over him. That’s not a successor ground. In re Majors, 2019 U.S. App. LEXIS 30504 (6th Cir. Oct. 10, 2019).*

Defendant sought to withdraw his plea by including an attack on defense counsel’s failure to file a Franks challenge, but he says nothing to show that it would be granted. State v. Sellman, 2019-Ohio-4185, 2019 Ohio App. LEXIS 4267 (2d Dist. Oct. 11, 2019).*

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