CA4: GFE applied to SW application without PC but where two state court warrants followed up based on it

The government concedes there was no probable cause for the search warrant here, but two state judges also renewed the warrants based on the first one. That’s good faith. United States v. Jordan, 2023 U.S. App. LEXIS 2655 (4th Cir. Feb. 2, 2023). [So three wrongs make a right?]

Probable cause includes reasonable suspicion. The officer had probable cause defendant fired a gun in violation of local ordinance. United States v. Abusnena, 2023 U.S. App. LEXIS 2660 (4th Cir. Feb. 2, 2023).*

Officer’s testimony that he obtained a search warrant for an address that wasn’t even defendant’s did not constitute hearsay nor did it destroy the presumption of innocence. [It was mere basis of action.] State v. Aekins, 2023-Ohio-322, 2023 Ohio App. LEXIS 301 (10th Dist. Feb. 2, 2023).*

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