Defense counsel wasn’t ineffective for not moving to suppress the seizure of boxes of evidence from defendant’s car. It was reasonable for the officers to believe defendant was loading the car to move evidence to hide it when the police arrived. United States v. Miller, 2020 U.S. App. LEXIS 9613 (D.C. Cir. Mar. 27, 2020).
Even if defendant’s TSA encounter was an unconstitutional seizure, his subsequent interview with police was shown to be attenuated. United States v. Gordon, 2020 U.S. App. LEXIS 9633 (1st Cir. Mar. 27, 2020).*