FL2: State’s failure to make record on GFE gets remand

The trial court’s failure to address the good faith exception as an alternative to alleged lack of probable cause precludes the state from relying on it. Remanded to make a record. Hicks v. State, 2020 Fla. App. LEXIS 2465 (Fla. 2d DCA Feb. 28, 2020).

The close relationship between the local humane society and the state makes the society’s actions state action for § 1983 and the Fourth Amendment. Plaintiff stated a claim against them for seizing and euthanizing his dogs. Newsome v. Bogan, 2020 U.S. App. LEXIS 6083 (2d Cir. Feb. 28, 2020).

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