Defendant was convicted of strangulation of a family member. The family member reported to the police that he had been in counseling and was keeping a detailed journal trying to break the cycle of domestic abuse. The affidavit for the warrant showed nexus and reason to believe that the journal would contain evidence of the crime. Kreusel v. State, 2023 WY 9, 2023 Wyo. LEXIS 9 (Jan. 27, 2023).
“’[C]ourts have previously determined that delays of 10 months, or more, in reviewing electronic data are not per se unreasonable, even when the government does not furnish a basis for the delay in searching electronic data.’ Estime, 2020 U.S. Dist. LEXIS 191242, 2020 WL 6075554, at 14 (collecting cases).” This delay was less and wasn’t unreasonable. United States v. Alexandre, 2023 U.S. Dist. LEXIS 13801 (S.D.N.Y. Jan. 26, 2023).
Defense counsel wasn’t ineffective for not challenging the search incident of the car for a gun when he was a felon in possession. Those facts are shown by the plea agreement and the PSR. Johnson v. United States, 2023 U.S. Dist. LEXIS 13426 (E.D. Mo. Jan. 26, 2023).*