Defense counsel wasn’t ineffective for not objecting to the search warrant because it would contradict his claim of self-defense. State v. Messenger, 2021-Ohio-2044, 2021 Ohio App. LEXIS 2017 (10th Dist. June 17, 2021) (see § 60.19)
The issue here is whether an attic separate from an apartment was a common area where the defendant’s upstairs apartment was the subject of the warrant. It could have been a common area, but the door was locked and broken into, and the state put on no proof about it being a common area. The attic part of the search is suppressed. People v. Moore, 2021 NY Slip Op 03975, 2021 N.Y. App. Div. LEXIS 4074 (4th Dept. June 17, 2021).
Defendant’s showing up for an arranged drug deal was probable cause to search the car he was driving. With no evidence to the contrary, the vehicle is presumed mobile for the automobile exception. United States v. Sandeen, 2021 U.S. Dist. LEXIS 113200 (D. Haw. June 16, 2021).*