D.Conn.: False dog alert may not mean anything

Alleged false alerts of a drug dog may not be at all because the dog could have smelled residual odor of drugs from some other time. United States v. Manson, 2023 U.S. Dist. LEXIS 138590 (D. Conn. Aug. 9, 2023) (“As the Supreme Court noted in Harris, a false alert may mean simply that the dog ‘smelled the residual odor of drugs previously in’ the location and thus ‘may not have made a mistake at all.’ 568 U.S. at 245-46.”).

Defendant’s motion to reconsider denial of his motion to suppress can’t simply reargue grounds already advanced and disposted of. United States v. Tsatenawa, 2023 U.S. Dist. LEXIS 138547 (W.D. Tex. Aug. 8, 2023).*

Defendant’s claim that the search warrant for another person’s house that he has no connection to would show potential outrageous governmental conduct as to him was too tenuous to even get discovery of the papers for that warrant. He was also detained on reasonable suspicion when he showed up there during the search. United States v. Collins, 2023 U.S. Dist. LEXIS 138550 (N.D. Fla. Aug. 4, 2023).*