PR Const. on evidentiary exclusion for 4A violation applies in forfeiture cases

Under the Puerto Rico Constitution, unlawfully seized evidence is inadmissible, and this includes forfeiture cases. Cruz v. Commonwealth 2025 PR App. LEXIS 2293 (Sept. 23, 2025).

The probable cause question here doesn’t have to be decided. Suffice it to say that there’s enough that it’s in good faith. United States v. Bridges, 2025 U.S. Dist. LEXIS 201510 (E.D. Mich. Oct. 10, 2025).*

CoA denied. “Jones has not made the requisite showing. See Slack, 529 U.S. at 484. We do not consider his newly raised claims that defense counsel’s purported ineffectiveness constitutes ‘cause’ to excuse his procedurally defaulted claims, that his counsel was ineffective in failing to raise a Fourth Amendment claim at trial ….” Jones v. Mississippi, 2025 U.S. App. LEXIS 26557 (5th Cir. Oct. 10, 2025).*

Plaintiffs state enough of a continued seizure in a traffic stop to get to a jury. Rodriguez had been decided before this happened. Caton v. Salamon, 2025 U.S. App. LEXIS 26546 (6th Cir. Oct. 10, 2025).*

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