Just saying in a motion to suppress the defendant “‘denies telling law enforcement that additional drugs could be found within his apartment’ and ‘disputes the accuracy’ of the statement that officers detected the odor of burnt marijuana in the apartment” isn’t enough for a Franks challenge. There has to be some offer of proof. United States v. Matthews, 2020 U.S. Dist. LEXIS 115695 (D. Del. July 1, 2020).
Defendant failed to show defense counsel was ineffective for how he argued a probation search. Campbell v. State, 2020 Del. LEXIS 227 (July 1, 2020).*