A domestic abuse victim police encountered bleeding outside had apparent authority to consent to an entry and search of the property. As the police came up, she said “He beat me bad this time.” Quintero v. Vega, 2021 U.S. Dist. LEXIS 107827 (E.D. Wis. June 7, 2021).
Police received a second hand 911 call about domestic violence in a home. Their warrantless entry was justified. Defendant had a gun and wouldn’t separate from his victim until the officers pulled their own. United States v. Goins, 2021 U.S. Dist. LEXIS 107892 (E.D. Mich. June 9, 2021).
Defendant made an offer of proof of a Franks violation, but the court finds it inadequate to show materiality. United States v. Patterson, 2021 U.S. Dist. LEXIS 107266 (W.D. Va. June 7, 2021).*
Petitioner’s habeas claim that what might be triple hearsay for a warrant is speculative on this showing and rejected as seeking an advisory opinion. Clary v. Salmonson, 2021 Mont. LEXIS 529 (June 8, 2021).*