Defendant was searched and arrested for a concealed weapon. That did not prohibit the officers from further searching his personal effects in his clothes. State v. Zepernick, 2021-Ohio-719, 2021 Ohio App. LEXIS 724 (7th Dist. Mar. 4, 2021).
2254 petitioner’s automobile exception search claim was barred by Stone v. Powell. His Franks claim [considered on the merits] fails for no offer of proof. Vicarini v. West, 2021 U.S. Dist. LEXIS 46332 (D. Md. Mar. 11, 2021).*
2255 petitioner shows enough of a factual dispute to get a hearing on defense counsel’s failure to file a motion to suppress a consent search alleged to not be consensual at all. A hearing will be needed on the merits of the Fourth Amendment claim. Carney v. United States, 2021 U.S. Dist. LEXIS 46411 (E.D. Tenn. Mar. 10, 2021).*