“[W]e find that a motion for the return of seized property may be a viable means to request the return of property even after conviction. Therefore, the trial court erred when it denied Mr. Castagnola’s motion for the return of seized property based on its presumed lack of jurisdiction to consider the motion.” State v. Castagnola, 2020-Ohio-1096, 2020 Ohio App. LEXIS 1004 (9th Dist. Mar. 25, 2020).
Defendant raises a Fourth Amendment and ineffective assistance of counsel claim about a search and seizure never raised before. It’s denied because it lacks merit even if it could be brought. Sanders v. United States, 2020 U.S. Dist. LEXIS 51936 (S.D. Ga. Feb. 10, 2020),* adopted, 2020 U.S. Dist. LEXIS 48971 (S.D. Ga. Mar. 12, 2020).*