“Officer Estrada’s reasonable suspicion ripened into probable cause when Shelton attempted to flee, thus giving rise to the exigent circumstances necessary for Officer Estrada to pursue Shelton onto the property without a warrant.” United States v. Shelton, 2020 U.S. App. LEXIS 19430 (10th Cir. June 23, 2020).
Defendant can’t show defense counsel was ineffective for not pursuing a suppression motion because he can’t show he had standing to show he might have prevailed. United States v. Powell, 2020 U.S. Dist. LEXIS 108246 (E.D. Mich. June 19, 2020).*
When the CI makes controlled buys that are used to get a search warrant and the defendant is charged with possession, not the controlled buys, the CI is not a material witness. United States v. Neal, 2020 U.S. App. LEXIS 19302 (8th Cir. June 22, 2020).*