CA4: If you’re going to call the search “egregious,” at least cite a case

“Dr. Dong next asserts, without citation to case law, that ‘[e]gregious procedural deficiencies in the investigation, prosecution, trial and sentencing’ occurred such that his convictions and sentence must be reversed. Opening Br. 18. He first points to alleged deficiencies in the affidavit supporting Special Agent Leonard’s application for a search warrant during the investigative phase of this case. Having reviewed Special Agent Leonard’s affidavit, we agree with the district court that the affidavit and resulting search warrant complied with the Fourth Amendment. …” United States v. Dong, 2022 U.S. App. LEXIS 5314 (4th Cir. Feb. 28, 2022).*

“In sum, there was reasonable suspicion on three independent grounds: (a) the silver Lincoln’s attempted flight; (b) the officers’ knowledge about the controlled purchase of heroin from Green by the CS and their reasonable suspicion that Green was replenishing his heroin supply; and (c) the observations of marijuana smoke and odor.” There was no seizure until he was captured after the flight. United States v. Green, 2022 U.S. Dist. LEXIS 33933 (W.D.Pa. Feb. 25, 2022).*

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