E.D.Tex.: Def’s attempts to distinguish Hudson and no ER for knock-and-announce fails

Defendant’s efforts to distinguish Hudson and its refusal to apply the exclusionary rule to knock-and-announce violations fail. United States v. Pyles, 2020 U.S. Dist. LEXIS 169623 (E.D. Tex. Sept. 16, 2020).

Petitioner gets a CoA on the following habeas issue: “Whether the district court violated Clisby v. Jones, 960 F.2d 925 (11th Cir. 1992) (en banc), by failing to address Petitioner’s claim that counsel was ineffective for failing to address the confidential informant’s credibility, including his testimony about the amount of drugs involved?” Williams v. United States, 2020 U.S. App. LEXIS 29600 (11th Cir. Sept. 16, 2020).* [That sounds too simplistic to me: It’s the officer’s addressing CI credibility in the affidavit, actually.]