“Galloway next argues that the district court erred in denying his motion to suppress because the IRS’s warrantless inspection of his financial records violated his private-property interests under the Fourth Amendment. But Galloway ‘never requested suppression on this ground in the district court,’ see United States v. Guerrero, 921 F.3d 895, 896-97 (9th Cir. 2019), petition for cert. filed, (U.S. Nov. 27, 2019) (No. 19-6825), and therefore Federal Rule of Criminal Procedure 12(c)(3) provides that we may only consider his untimely claim if he shows ‘good cause for failing to present in his pre-trial motion the new theory for suppression he raises in this appeal,’ id. at 898. Because Galloway failed to show good cause, we affirm the district court’s denial of his motion to suppress.” United States v. Galloway, 2020 U.S. App. LEXIS 3976 (9th Cir. Feb. 6, 2020).
The officer here investigated an attorney for something outside the officer’s jurisdiction, and that served to deny the officer qualified immunity. Robinson v. Ash, 2020 U.S. App. LEXIS 4067 (11th Cir. Feb. 11, 2020).*