CA2: No 4A extraterritorial jurisdiction over Switzerland enforcing its own law against Americans in Switzerland

An extraterritorial seizure of art work and antiquities in Switzerland of American citizens doesn’t involve the Fourth Amendment. International law has not adopted the Fourth Amendment’s probable cause standard. There is no justification shown for applying the Fourth Amendment to Switzerland’s activities there or meddling in their investigation. Beierwaltes v. L’Office Federale de la Culture de la Confederation Suisse (Fed. Office of Culture of the Swiss Confederation), 2021 U.S. App. LEXIS 16942 (2d Cir. June 8, 2021).

Filing a CSLI motion pre-Carpenter was a futile act for defense counsel, so there was no ineffectiveness. People v. Cerda, 2021 IL App (1st) 171433, 2021 Ill. App. LEXIS 282 (June 3, 2021).*

Just because defendant’s alleged drug operation was located in his apartment, that didn’t mean the officers did not also have probable cause as to his car. They did. Commonwealth v. Ortiz, 2021 Mass. LEXIS 345 (June 8, 2021).*

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