A summons to appear is not a seizure. Jianjun Li v. Village of Saddle Rock, 2021 U.S. Dist. LEXIS 60705 (E.D. N.Y. Mar. 30, 2021).
New York statute that special prosecutors have to give notice to elected DAs about, inter alia, search warrant requests is notice only – not getting permission. People v. Viviani, 2021 NY Slip Op 01934, 2021 N.Y. LEXIS 500 (Mar. 30, 2021).*
Defendant’s ineffective assistance of counsel claim for not challenging a search fails because his own evidence shows multiple reasons why the search was valid. United States v. Wyche, 2021 U.S. Dist. LEXIS 60701 (E.D. Va. Mar. 29, 2021).*
There was at the minimum implied consent for officers to enter. There was also exigency shown. United States v. Buck, 2021 U.S. Dist. LEXIS 60418 (C.D. Cal. Mar. 24, 2021).*