Bivens should not be extended to an immigration detention. K.O. v. Sessions, 2022 U.S. App. LEXIS 20984 (D.C. Cir. July 29, 2022).
Plaintiff filed a § 1983 case against his prosecution which fails on Younger grounds. As to an illegal search claim, it is disposed of on qualified immunity and failure to state anything close to a claim without even discussing Heck or Younger. Kabutu v. Short, 2022 U.S. App. LEXIS 20997 (10th Cir. July 29, 2022).
Defendant makes a rule-based challenge to a search. “Because the Fourth Amendment issue lacks cogent reasoning and the issue raised under Article I, § 11 is not separately analyzed, we find them waived.” Weed v. State, 2022 Ind. App. LEXIS 264 (July 29, 2022).*