CA1: Franks offer of proof didn’t show materiality or undermine PC

Defendant’s appeal is based on his claim that the district court erred in not holding a Franks hearing. Defendant didn’t show enough in his allegations to show that the omissions were material to the showing of probable cause. United States v. Veloz, 2020 U.S. App. LEXIS 2290 (1st Cir. Jan. 24, 2020).

The search warrant for defendant’s car was properly issued with probable cause because FBI surveillance and pole camera observations showed that defendant drove from New York City to Revere and Boston, Massachusetts, and never stayed in Revere more than 30-40 minutes. There was also informant information these were drug runs and CSLI (from 2015) on his movements. United States v. Bregu, 2020 U.S. App. LEXIS 2288 (1st Cir. Jan. 24, 2020).*

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