A second officer running warrants on detainees from a justified vehicle stop did not have anything to do with the original mission of the stop. “Officer Hogan questioned the passenger while Officer Holland dealt with Brewer, and we do not see how Officer Hogan’s separate conversation delayed Holland’s investigation or the stop as a whole.” There was also reasonable suspicion the occupants were armed. United States v. Brewer, 2021 U.S. App. LEXIS 17130 (6th Cir. June 7, 2021).
Habeas petitioner completely fails to show that any of the suppression grounds he raises would have been granted if they were made dooms his IAC claim. Montelongo-Rangel v. Warden, 2021 U.S. Dist. LEXIS 106969 (S.D. Ohio June 7, 2021).*
There was nexus between defendant’s controlled buy and a rental car to justify a tracking warrant for the car. Omitting the name of the renter of the car wasn’t material because they officer didn’t know it. The warrant for a motel room was not stale because it was based on his using the motel repeatedly for drug transactions over the previous few months. United States v. Brown, 2021 U.S. Dist. LEXIS 107228 (D. Vt. June 8, 2021).*