LA1: Claim probation violation warrant lacked justification that led to search incident has to be argued on appeal

Defendant claimed his probation violation arrest warrant was defective and then argued the search incident to his arrest was thus invalid. On appeal, he doesn’t argue the validity of the arrest warrant, so the argument is waived. State v. Anglin, 2020 La. App. LEXIS 683 (La. App. 1 Cir. May 11, 2020).

“The fact that Edwards was not named in the search warrant for 803 Slate Lick Road does not provide a basis for challenging the search. … ‘[S]earch warrants are not directed at persons; they authorize the search of place[s] and the seizure of things, and as a constitutional matter they need not even name the person from whom the things will be seized.’ …” There was probable cause for his arrest for a felony, and an arrest warrant wasn’t required. United States v. Edwards, 2020 U.S. App. LEXIS 15216 (6th Cir. May 12, 2020).*