S.D.Ill.: Extrinsic evidence is admissible in a Franks challenge

Extrinsic evidence of alleged falsity in a Franks challenge is admissible. United States v. Smith, 2022 U.S. Dist. LEXIS 234002 (S.D. Ill. Dec. 20, 2022).

Questioning defendant about the presence of a firearm in his vehicle fell within the Quarles public safety exception. United States v. Griffin, 2022 U.S. Dist. LEXIS 233992 (S.D. Ill. Dec. 31, 2022).

Defendant is a Russian national indicted for hack-and-trade securities fraud. Probable cause was shown for a search warrant for his iCloud account. The good faith exception would apply in any event. United States v. Klyushin, 2022 U.S. Dist. LEXIS 233870 (D. Mass. Dec. 2, 2022).*

“But our review of the affidavit shows that even with the addition of the omitted information, the affidavit still establishes probable cause to arrest Frantz for first-degree premeditated murder.” State v. Frantz, 2022 Kan. LEXIS 124 (Dec. 30, 2022).*

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