GA: Controlled buy by CI corroborates CI and is PC in itself

“‘Under the common sense approach to search warrants, a controlled buy strongly corroborates the reliability of the informant and shows a fair probability that the contraband would be found.’… Indeed, ‘even if the informant had no known credibility, the controlled buy conducted under the observation of the officer alone, would have been sufficient to establish probable cause.’” Woods v. State, 2018 Ga. App. LEXIS 371 (June 15, 2018).*

Defendant can’t show ineffective assistance of counsel from defense counsel’s handling of a Franks issue on appeal. The alternative argument he claims should have been raised would have fared worse. Engle v. Davis, 2018 U.S. Dist. LEXIS 101492 (N.D. Tex. June 18, 2018).*

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