NY3: CI’s alleged false statement wasn’t enough to suppress

As to an alleged false statement by the CI, it didn’t undermine the probable cause finding. People v. Cazeau, 2021 NY Slip Op 01806, 2021 N.Y. App. Div. LEXIS 1947 (3d Dept. Mar. 25, 2021) (nearly four years from judgment to appeal affirmed).

Defendant doesn’t show ineffectiveness in not challenging a consent search. He signed and initialed the consent form which was in Spanish. “Because movant would not have had an appreciable chance of success on a motion to suppress, he cannot prevail.” Soto-Silva v. United States, 2021 U.S. Dist. LEXIS 56464 (N.D. Tex. Mar. 25, 2021).*

Defense counsel wasn’t ineffective for not filing a motion to suppress a search where defendant couldn’t show a reasonable expectation of privacy in the place searched. Delva v. United States, 2021 U.S. App. LEXIS 8721 (11th Cir. Mar. 25, 2021).*

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