Based on the officer’s observation of baggies of drugs hanging out of a bookbag, the contents were readily apparent. State v. Burroughs, 2020-Ohio-4417, 2020 Ohio App. LEXIS 3301 (3d Dist. Sept. 14, 2020).
Defendant’s objection to the R&R had a new Fourth Amendment argument. Considered on the merit [which the court didn’t have to do], it is denied because the wiretap order wasn’t violated. United States v. Stubbs, 2020 U.S. Dist. LEXIS 166897 (D. Nev. Sept. 11, 2020).*
Plaintiff’s Franks challenge in this Bivens case over an extortion bank robbery is actually a challenge to the conviction which is barred by Heck. Benanti v. Poynter, 2020 U.S. Dist. LEXIS 166995 (W.D.N.C. Sept. 11, 2020).*