A “Brinks box” in the house being searched with a warrant for drugs was subject to the search. United States v. Simmermaker, 2019 U.S. Dist. LEXIS 199422 (N.D. Iowa Oct. 25, 2019), adopted, 2019 U.S. Dist. LEXIS 198379 (N.D. Iowa Nov. 15, 2019).
2255 petitioner didn’t show ineffective assistance of counsel from defense counsel’s failure to move to suppress the search warrant in his case. The affidavit for the warrant shows probable cause, and it’s also apparent the good faith exception applies. Moreover, petitioner can’t show prejudice: “Thus, even a successful challenge to the search would not have prevented the Government from charging Petitioner with up to 15 narcotics transactions, leaving Petitioner in potentially more legal jeopardy. Thus, in the absence of any prejudice from Petitioner’s supposed ineffectiveness, Petitioner’s claim fails.” Scott v. United States, 2019 U.S. Dist. LEXIS 198289 (S.D.N.Y. Nov. 14, 2019).*