Assuming, without deciding, that obtaining defendant’s CSLI in a knife attack case was unreasonable, it was harmless error on this record. Plenty of other evidence connected him. People v. Perez, 2020 NY Slip Op 02684, 2020 N.Y. App. Div. LEXIS 2818 (3d Dept. May 7, 2020).
Pleading guilty waived defendant’s Franks challenge. United States v. Granville, 2020 U.S. Dist. LEXIS 79866 (D. Ore. May 6, 2020).*
Any allegedly false statements in the affidavit for search warrant aren’t shown to be intentionally or recklessly made. Moreover, probable cause remains even if those statements are disregarded. Franks challenge fails. United States v. Lewis, 2020 U.S. Dist. LEXIS 79813 (E.D. Mo. Apr. 15, 2020).