LA5: Two CIs provided RS for def’s vehicle stop without need for traffic offense

The trial court’s denial of suppress is affirmed. There were two CIs. One provided details about defendant’s drug operation and the places and vehicles involved. The other provided predictive information that panned out. By the time defendant’s vehicle was stopped, there was reasonable suspicion, and an actual traffic offense was not required. State v. Abrego, 2021 La. App. LEXIS 1852 (La. App. 5 Cir. Dec. 1, 2021).

2255 petitioner’s generalized claim of ineffective assistance of counsel for a search claim fails. Defense counsel litigated a motion to suppress which was denied. It can’t be re-raised in a 2255. United States v. Meadows, 2021 U.S. Dist. LEXIS 233549 (N.D.Ohio Dec. 7, 2021).*

Having smelling marijuana during a traffic stop, the officer asked the defendant to get out of the car. A bag of heroin was in plain view. State v. Brunk, 2021-Ohio-4270, 2021 Ohio App. LEXIS 4163 (5th Dist. Dec. 6, 2021).*

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