S.D.Ala.: Younger doctrine precludes ptf’s 4A claim over pending state criminal case

Plaintiff’s false arrest claim claiming, inter alia, a Fourth Amendment violation, two years into his pending state criminal case was barred by the Younger doctrine. Sweeting v. Garrett, 2021 U.S. Dist. LEXIS 66705 (S.D. Ala. Apr. 6, 2021).

Under Washington’s privacy act, a body wire order was shown reasonably necessary for the CI’s safety. The need for a showing isn’t high, but it needs to show more than just general truisms. State v. Gonzalez, 2021 Wash. App. LEXIS 779 (Apr. 6, 2021).*

The affiant showed probable cause for the search warrant. “Here, there are at least 13 instances between March and late May 2019 which implicated 69 Cutler Street as premises where it was reasonable to assume that evidence of drug deals would be found. The issuing magistrate judge had more than sufficient probable cause to believe that evidence of drug trafficking would be found at 69 Cutler Street.” The good faith exception also applies. United States v. Rodriquez, 2021 U.S. Dist. LEXIS 66504 (D. Mass. Apr. 5, 2021).*

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