ICE was monitoring credit card purchases from a child pornography website. Defendant purchased using an e-mail address and a credit card. The IP address of the e-mail was traced to defendant\u2019s house. That provided probable cause for a search warrant for the house and its computers. United States v. Skjonsby, 2011 U.S. Dist. LEXIS 16546 (D. Minn. January 14, 2011).*<\/p>\n
Defense counsel was not ineffective for not calling witnesses at a Franks hearing since he could not even make a threshold showing to get a Franks hearing anyway. The falsities he was relying on were insufficient to undermine probable cause. Smith v. United States, 2011 U.S. Dist. LEXIS 16366 (E.D. Mo. February 18, 2011).*<\/p>\n
Officers called out to the defendant to attempt to get him to stop as he approached a drug house late at night. There was no reasonable suspicion, but defendant ignored them and tossed a gun and drugs against the fence as he went into the house. That was an abandonment and created justification for his stop. United States v. Fowler, 2011 U.S. Dist. LEXIS 16526 (D. Neb. February 18, 2011).*<\/p>\n
Crediting their testimony, officers had reasonable suspicion to stop defendant and probable cause to search his Escalade. United States v. Cummings, 764 F. Supp. 2d 480 (E.D. N.Y. 2011).*<\/p>\n
Defendant was stopped because he was a suspect in a bank robbery with probable cause, so the search of the car was not limited by the search incident doctrine. United States v. Miller, 2011 U.S. Dist. LEXIS 16751 (S.D. Ind. February 19, 2011).*<\/p>\n","protected":false},"excerpt":{"rendered":"
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