CA11: Including omitted information under Franks still left PC

The omission here was not a Franks violation. “Here, even if Jackson’s statement had been included in the affidavit, it would not have tipped the balance. The officers still would have had probable cause to search the home, because the totality of the circumstances indicated a fair probability—at least—of finding contraband or evidence in the home.” United States v. Leonard, 2021 U.S. App. LEXIS 20267 (11th Cir. July 8, 2021).*

“The case at bar does not present any circumstance that warrants suppression. Although the Court harbors doubts about the warrant’s support, the Affidavit was not so lacking in indicia of probable cause as to make belief in its existence objectively unreasonable. In addition, the warrant was not so facially deficient in terms of particularity as to preclude good faith reliance thereon.” United States v. Bowers, 2021 U.S. Dist. LEXIS 127037 (W.D. Pa. July 8, 2021).*

IP subscriber information is not protected by the Fourth Amendment. United States v. Bowers, 2021 U.S. Dist. LEXIS 127036 (W.D. Pa. July 8, 2021).*