M.D.Ala.: No constitutional requirement that the SW be served on the target of the search, so the missing attachment didn’t matter

There is no constitutional requirement that the search warrant be served on the target of the search, so the missing attachment didn’t matter. “As stated above, the record demonstrates with reasonable certainty that a warrant stating with particularity the items to be seized, in compliance with the Fourth Amendment, existed when entrance was made to conduct the search of Leflore’s residence. Therefore, Leflore fails to demonstrate that the Fourth Amendment argument he now makes is meritorious. And as a consequence, he also fails to establish that his counsel performed deficiently by failing to challenge the search of his residence on the grounds he now presents, or that he was prejudiced by his counsel’s failure to do so. Leflore is entitled to no relief on this claim of ineffective assistance of counsel.” Leflore v. United States, 2020 U.S. Dist. LEXIS 7002 (M.D. Ala. Jan. 14, 2020).

“In any event, for reasons discussed below, reasonable jurists would agree that Price failed to show that counsel performed deficiently by failing to challenge the search warrant, because Price has not identified any meritorious claim that counsel could have raised.” Price v. United States, 2020 U.S. App. LEXIS 1416 (6th Cir. Jan. 15, 2020).*