Defendant was arrested and searched incident to arrest, and the court finds no valid basis for the search. He was too far away from and out of sight of the drugs the government was attempting to link to him. United States v. Sanders, 2021 U.S. Dist. LEXIS 127697 (W.D. N.Y. July 8, 2021).
In the Waco Twin Peaks shooting arrest where 177 people were arrested for motorcycle gang affiliation and thus gang crimes, and no one was convicted, a Franks claim was stated as to a [rather shallow] bform arrest warrant that become woefully insufficient as to many of them. Qualified immunity denied. Remanded. Terwilliger v. Reyna, 2021 U.S. App. LEXIS 20322 (5th Cir. July 8, 2021).*
Defendant’s ineffective assistance of counsel claim is outside the record and can’t be raised on direct appeal. State v. Jordan, 2021-Ohio-2332, 2021 Ohio App. LEXIS 2299 (2d Dist. July 9, 2021).*