Defense counsel wasn’t ineffective for not seeking a Franks hearing where there was no search warrant in the first place. Freeman v. United States, 2019 U.S. Dist. LEXIS 187171 (N.D. Ill. Oct. 29, 2019).
Defendant’s general consent to search a duffle bag for narcotics included consent to search a ledger book found in the bag, too. United States v. Colin, 2019 U.S. Dist. LEXIS 187054 (W.D. Tex. Oct. 29, 2019).*
A motion to suppress filed four days before trial is denied as untimely. United States v. Villa-Guillén, 2019 U.S. Dist. LEXIS 185672 (D.P.R. Oct. 28, 2019).*