Defendant had been arrested and handcuffed and officers had weapons drawn, and he hadn’t yet been Mirandized. Still, on the totality, he consented to the search. United States v. Collins, 2023 U.S. App. LEXIS 1257 (2d Cir. Jan. 19, 2023).
Waiting three years after execution of the search warrant on defendant did not prove that he wasn’t a danger to the community for release purposes when he was finally picked up. United States v. Drake, 2023 U.S. Dist. LEXIS 8273 (W.D. Va. Jan. 12, 2023).*
Plaintiff’s arrest on a warrant that did not go behind the probable cause determination made for it states no claim against the arresting officers. King v. Utt, 2023 U.S. App. LEXIS 1317 (4th Cir. Jan. 19, 2023).*