CA11: Change in strategy doesn’t excuse untimely motion to suppress

With second counsel, defendant filed a second motion to suppress apparently based on new strategy about how to approach one. The different strategy is not “good cause” based on newly discovered facts. United States v. Vazquez, 2023 U.S. App. LEXIS 7286 (11th Cir. Mar. 28, 2023).

In a “sexual services” investigation, the officer showed probable cause and nexus for multiple locations and vehicles. Commonwealth v. Hayes, 2023 Mass. App. LEXIS 47 (Mar. 28, 2023).*

The video showed reasonable suspicion for defendant’s stop. United States v. Waldeck, 2023 U.S. Dist. LEXIS 52138 (D. Mont. Mar. 27, 2023).*

Claimant’s suitcase reeked of marijuana when he went through a TSA checkpoint, and the x-ray revealed “organic masses” which turned out to be marijuana. The opening of the bag and search were reasonable under the Fourth Amendment. United States v. $115,413.00 in U.S. Currency, 2023 U.S. Dist. LEXIS 52249 (E.D.N.C. Mar. 28, 2023).*

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