The protective sweep finding defendant’s guns on execution of his arrest warrant was reasonable. Defendant does not show that the officers intentionally delayed his arrest with the purpose of exploiting a protective sweep. United States v. Cammon, 2021 U.S. App. LEXIS 7094 (6th Cir. Mar. 9, 2021).
Defendant’s argument shifted from a Franks challenge to a straight probable cause challenge. None of the alleged omissions were material. Denied. United States v. Coleman, 2021 U.S. Dist. LEXIS 45802 (N.D. Ind. Mar. 11, 2021).*