A 13 day delay between a trash pull and a search warrant didn’t make the trash pull stale. There was an ongoing investigation throughout. United States v. Dobbs, 2023 U.S. Dist. LEXIS 52882 (E.D. Mich. Mar. 28, 2023).
District court’s suppression order for coercing consent was reversed. The court of appeals takes a different view of the words used as a threat to get a warrant, which they had cause to do. United States v. Jacobs, 2023 U.S. App. LEXIS 7317 (6th Cir. Mar. 28, 2023).*
Defendant wasn’t entitled to a new trial based on an alleged newly discovered search warrant having been executed. The defense was always on notice of that, so denied. Reyes v. United States, 2023 U.S. Dist. LEXIS 52510 (D. Conn. Mar. 28, 2023).*