Having pled guilty in state court, plaintiff can’t complain that the arrest leading to the plea lacked probable cause. Moser v. Davis, 2021 U.S. Dist. LEXIS 13308 (E.D. Tenn. Jan. 25, 2021).
Petitioner had a “full and fair” opportunity to litigate his Fourth Amendment in state court, which he did and lost. “In any event, the record does not indicate that the state courts ignored federal law or support a claim of ‘egregious error.’” Barnhart v. Warden, 2021 U.S. Dist. LEXIS 12966 (S.D. Ohio Jan. 25, 2021).*
Police responding to a specifically described man with a gun saw petitioner exactly matching with a suspicious bulge at his waist. He saw the police and fled, tossing the gun, which the police recovered. Defense counsel wasn’t ineffective for not challenging the alleged search. He was never seized when he fled and abandoned property. Haynes v. United States, 2021 U.S. Dist. LEXIS 13058 (D. N.J. Jan. 25, 2021).*