2255 petitioner’s failure to argue he told defense counsel that his consent to search was involuntary was fatal to his claim defense counsel was ineffective for not arguing it. United States v. Mitchell, 2020 U.S. Dist. LEXIS 123319 (E.D. Mich. July 14, 2020).
A claim of false arrest and unreasonable detention of a U.S. citizen entering the Mexican border by CBP should not be recognized under Bivens, after Hernandez v. Mesa. Johnson v. United States, 2020 U.S. Dist. LEXIS 123610 (S.D. Cal. July 14, 2020).
State’s failure to argue standing in the trial court is waiver. State v. K.E.L., 2020 Ala. Crim. App. LEXIS 50 (July 10, 2020) (recognizing rule).*