TN: Even if search occurred before SW issued, affidavit mentions nothing of it; thus independent source

Defendant claimed that his place was warrantlessly searched before the search warrant for it was issued. Doesn’t matter: The affidavit for the warrant shows probable cause and never mentions a prior search. State v. Quinn, 2024 Tenn. Crim. App. LEXIS 113 (Mar. 13, 2024).

Defendant is a doctor who arranged a hit on the dark web that British authorities alerted the FBI to. His Fourth Amendment claim in his 2255 is barred. United States v. Ilg, 2024 U.S. Dist. LEXIS 44751 (E.D. Wash. Mar. 13, 2024).*

“Based on our in camera review of the unredacted search warrant application and the minutes of the examination of the confidential informant by the issuing court, we find that there was probable cause to issue the warrant ….” People v. Coleman, 2024 NY Slip Op 01350, 2024 N.Y. App. Div. LEXIS 1351 (1st Dept. Mar. 14, 2024).*

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