Plaintiff as a trespasser had no reasonable expectation of privacy to make a Fourth Amendment complaint. “Just as a trespasser has no reasonable expectation of privacy in the property, a trespasser also lacks a possessory interest in the property. The very definition of ‘trespass,’ after all, is the interference of another’s possessory interest.” “Even if Dix alleged that there was a Fourth Amendment ‘seizure,’ to ‘state a constitutional violation,’ he must also allege that ‘the seizure … was “unreasonable.”’ … Case law compels our next conclusion: that even if a seizure occurred here, it was reasonable.” Dix v. Edelman Fin. Servs., 2020 U.S. App. LEXIS 32883 (7th Cir. Oct. 19, 2020).
2255 petitioner’s claim defense counsel was deficient in failing to investigate a Franks challenge fails on the merits of that challenge. Sims v. United States, 2020 U.S. Dist. LEXIS 192882 (N.D. Tex. Oct. 19, 2020).*