Defense counsel didn’t file a motion to suppress evidence because defendant’s stop likely was without reasonable suspicion, and a motion to suppress might well have been granted. However, there was a legitimate strategic reason for not moving to suppress which was successful; that evidence ultimately stayed out of the factual basis for the plea. United States v. Scott, 2020 U.S. Dist. LEXIS 36140 (E.D. La. Mar. 3, 2020).
Defense counsel’s failure to move to exclude evidence wasn’t ineffective assistance because there was no basis. Here, it was the seizure of items in plain view during execution of a warrant. United States v. Snowden, 2020 U.S. Dist. LEXIS 35933 (D.Nev. Mar. 2, 2020).*
The CI’s story that defendant sold drugs from his house was corroborated, credible enough, and showed probable cause. State v. Blaess, 2020 Iowa App. LEXIS 234 (Mar. 4, 2020).*