“The knowing and voluntary guilty plea waived all alleged ineffective assistance of counsel which preceded it, including counsel’s alleged deficiencies with regards to Fourth Amendment issues.” Allen v. United States, 2019 U.S. Dist. LEXIS 205762 (W.D. N.C. Nov. 26, 2019).
The exclusionary rule doesn’t apply in civil proceedings. Matter of Omnamm L. (Kumar L.), 2019 NY Slip Op 08563, 2019 N.Y. App. Div. LEXIS 8589 (2d Dept. Nov. 27, 2019).
“[W]e agree with the State that there was no Fourth Amendment seizure when the deputy approached the car and initially questioned Williams about her reason for being there. The car occupied by Williams was already stopped, the deputy did not activate his lights, and his vehicle technically gave the defendant a path of egress.” State v. Williams, 2019 Iowa App. LEXIS 1081 (Nov. 27, 2019).*