CA6: Pre-Carpenter cell site simulator use reasonable by GFE

Defendant’s 2255 claim that the government used a cell site simulator prior to Carpenter to capture his unlisted burner phone numbers is saved by the good faith exception. Powell v. United States, 2021 U.S. App. LEXIS 9850 (6th Cir. Apr. 5, 2021).

The issues underlying defendant’s ineffective assistance claim, including his Fourth Amendment claim, was resolved in his direct appeal and is thus denied. In re Hammond, 2021 U.S. App. LEXIS 9942 (11th Cir. Apr. 6, 2021).*

Plaintiff’s resisting arrest justified the use of a Taser. Cloud v. Stone, 2021 U.S. App. LEXIS 9955 (5th Cir. Apr. 6, 2021).*

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