CA2: Arrest for selling crack justifies search incident

Arrest for selling crack justified a search incident, and the district court erred in holding otherwise. United States v. Williams, 2020 U.S. App. LEXIS 6768 (2d Cir. Mar. 4, 2020).

The evidence supports the trial court’s conclusion the search was by consent. State v. Hill, 2020 La. App. LEXIS 365 (La. App. 2 Cir. Mar. 4, 2020).*

Defendant’s argument that defense counsel should have made a creative argument about advice of rights in a DUI investigation doesn’t show ineffective assistance of counsel. Schaul v. State, 2020 Iowa App. LEXIS 212 (Mar. 4, 2020).*

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