“Williams’ assertion that counsel failed to inform him that state law enforcement officers are not authorized to make federal arrests provides no support for a claim of ineffective assistance of counsel.” Considering the merits of any search claim, defendant’s stop was justified and the officer had probable cause to believe there were firearms in the car based on a corroborated confidential informant. United States v. Williams, 2020 U.S. Dist. LEXIS 63890 (D. Minn. Apr. 13, 2020).
Defense counsel failed to file a motion to suppress despite a 23 day delay in getting a search warrant to search defendant’s laptop already seized by the government. No prejudice. The government had accessed the computer on a P2P network and seen its contents before. Monetti v. United States, 2020 U.S. Dist. LEXIS 63287 (S.D. Fla. Apr. 9, 2020).