Omission of the CI’s prior convictions wasn’t material for Franks purposes. It was obvious he was helping himself out in making penal admissions, and his credibility was otherwise shown. The issuing magistrate would have still issued the warrant. United States v. Shultz, 2020 U.S. Dist. LEXIS 33960 (N.D. Ind. Feb. 27, 2020).
The district court erred in dismissing plaintiff’s unlawful arrest claim for false arrest for obstruction when he clearly did nothing wrong. Their drawing weapons on him, however, was justified. Mann v. Joseph, 2020 U.S. App. LEXIS 6073 (11th Cir. Feb. 28, 2020).*