Standard plea colloquy undercut the defendant’s claim of prejudice for an IAC claim that defense counsel missed a Fourth Amendment claim. Travis v. United States, 2008 U.S. Dist. LEXIS 11347 (E.D. Mo. February 14, 2008):<\/p>\n
THE COURT: Now, Miss Travis, are you satisfied with the representation you have received from Mr. Winston?<\/p>\n
THE DEFENDANT: Yes.<\/p>\n
THE COURT: Do you have any complaints whatsoever about his representation of you?<\/p>\n
THE DEFENDANT: No, Your Honor.<\/p><\/blockquote>\n
(Comment:<\/em> This doesn’t do a thing for the complaining defendant who only discovered defense counsel missed a Fourth Amendment claim after in the joint.)<\/p>\n
Reasonable suspicion certainly doesn’t take much, particularly when knowledge of the defendants include their families’ histories of violence, too. United States v. Headen, 264 Fed. Appx. 244 (3d Cir. 2008)* (unpublished):<\/p>\n
The District Court also correctly held that under the totality of the circumstances, the officers had reasonable suspicion to frisk Headen. Because of their participation in the Violent Crime Impact team in the neighborhood in which the stop occurred, Wescoe and McDermott both had specialized knowledge of the geographic area, the criminal activity in that area, and the individuals involved in that criminal activity. Despite Headen’s argument that the District Court erred in finding that Headen had been involved in gang activity, Wescoe and McDermott had previously investigated shootings in the area involving Headen and Mark Lawrence and the families and acquaintances of each. Furthermore, the officers were aware of Headen’s involvement in violent activity. <\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"
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