A Bivens remedy should not exist for actions against prisons for seizure of an inmate’s artwork that allegedly violated prison regulations. Courts don’t want to get into monitoring prisons. Callahan v. Fed. Bureau of Prisons, 2020 U.S. App. LEXIS 22115 (6th Cir. July 16, 2020).
Defendant pled guilty. Defense counsel was told of an error in the search warrant application by the DA, but didn’t pursue the issue to conclusion. Defendant can’t show that the error was dispositive of any search issue. People v. Powell, 2020 NY Slip Op 03999, 2020 N.Y. App. Div. LEXIS 4090 (1st Dept. July 16, 2020).*