W.D.N.Y.: A mere general statement in motion to suppress SW lacks PC doesn’t preserve the issue

Defendant’s general argument that probable cause was lacking for the search warrant in this case was inadequate to preserve the issue. Even considering the merits, there was probable cause. United States v. Dolson, 2019 U.S. Dist. LEXIS 216913 (W.D. N.Y. Oct. 19, 2019), adopted, 2019 U.S. Dist. LEXIS 216162 (W.D. N.Y. Dec. 16, 2019):

Even if he had established standing to contest the search, Dolson argues only generally that “[t]he search warrant authorizing the searches therefor was also not properly issued”, and that it was “based upon insufficient grounds, which did not satisfy probable cause for the issuance of a search warrant”. … “It is not enough merely to mention a possible argument in the most skeletal way, leaving the court to do counsel’s work.” United States v. Zannino, 895 F.2d 1, 17 (1st Cir. 1990). “Issues adverted to in a perfunctory manner, unaccompanied by some effort at developed argumentation, are deemed waived.” McPherson v. Kelsey, 125 F.3d 989, 995 (6th Cir. 1997). See also Flores v. Tryon, 2017 U.S. Dist. LEXIS 138411, 2017 WL 3705124, *3 n. 4 (W.D.N.Y. 2017) (“it is not this Court’s responsibility to raise and make counsel’s arguments for them”).

In any event, I see no basis to conclude that probable cause was lacking. …