Defendant’s possession of a blank rental agreement fell short of showing his standing to challenge the search of the car he was driving. Defendant has to go forward on standing somehow, and Byrd doesn’t say how. United States v. White, 2020 U.S. App. LEXIS 19618 (8th Cir. June 24, 2020).
Defendant claimed defense counsel was ineffective for not challenging the search. Considering the merits of the search claim, the court finds defendant would have lost on it, so no harm no foul. Collazo v. United States, 2020 U.S. Dist. LEXIS 110672 (M.D. Tenn. June 24, 2020).*