“The Presentence Reported noted that, after his arrest, Petitioner called an individual who was living at his home. Petitioner instructed this person to get rid of additional evidence that police had not found during the execution of the search warrant. Subsequently, officers went to the home and found a bag containing methamphetamine residue in the garbage.” That justified an obstruction enhancement under U.S.S.G. 3C1.1. Larsen v. United States, 2018 U.S. Dist. LEXIS 101012 (D. Utah June 18, 2018).
Petitioner claimed trial and appellate counsel didn’t adequately pursue his claim for suppression under the Posse Comitatus Act. Trial counsel did and lost, and after the district court rule, the Ninth Circuit foreclosed the argument in another case. Gentles v. United States, 2018 U.S. Dist. LEXIS 101351 (E.D. Mo. June 18, 2018).*