Defendant’s arrest under the Cleveland Mayor’s civil unrest proclamation was unreasonable, and the plain view was a result of the illegal arrest. United States v. Long, 2020 U.S. Dist. LEXIS 213676 (N.D. Ohio Nov. 16, 2020).
Petitioner generally claimed the affidavit for the search warrant in his case was insufficient to support an ineffective assistance claim. Defense counsel’s failure to file a motion to suppress isn’t per se ineffective assistance because there could be good reason not to. Slates v. United States, 2020 U.S. App. LEXIS 35820 (6th Cir. Nov. 13, 2020).*
The CI’s information started with “reliability” buys and then surveillance to back it up. There was probable cause and the good faith exception applies. United States v. Mitchell, 2020 U.S. Dist. LEXIS 213682 (W.D. Tenn. Nov. 16, 2020).*