Plaintiff has no standing to complain of a knock-and-announce violation of another person. “Here, Plaintiff does not even claim that he had a legitimate expectation of privacy in McMullen’s house. But even if he did make such a claim, the facts alleged in the Amended Complaint would not support it. By all appearances, Plaintiff has no relationship with McMullen or his family and had never been to McMullen’s house before the raid.” Murphy v. May, 2022 U.S. Dist. LEXIS 16468 (E.D.Mich. Jan. 28, 2022).
Plaintiff adequately pled for PLRA purposes a punitive strip search in jail. Gerez v. Castro, 2022 U.S. Dist. LEXIS 16427 (C.D.Cal. Jan. 28, 2022).*