Petitioner showed actual innocence to get his drug conviction set aside. The Houston officer involved was shown to be a perjurer in drug case search warrant requests and trial testimony. That led to two deaths during a botched no-knock drug raid. The officer was convicted for that, and that led to reexamining all his cases back to 2008, which included petitioner’s. Ex parte Mallet, 2020 Tex. Crim. App. LEXIS 503 (July 1, 2020) (with four concurrences).
Defendant’s trial court jurisdiction to issue a search warrant wasn’t raised below so it’s waived. State v. James, 2020 ND 136, 2020 N.D. LEXIS 146 (June 29, 2020).*
Defendant’s Franks challenge was waived for not presenting it in his motion to suppress. Even so, it’s unmeritorious. United States v. Dougherty, 2020 U.S. Dist. LEXIS 114950 (E.D. Pa. July 1, 2020).*