CA6: Def doesn’t show arrest was delayed to facilitate better protective sweep

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).*

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