Search warrant applications are reviewed on the “four corners” of the affidavit. “New evidence” isn’t considered. United States v. Shade, 2022 U.S. Dist. LEXIS 43451 (6th Cir. Mar. 9, 2022).
There was reasonable suspicion for the officer to expand the stop to a field sobriety test. State v. Clinger, 2022-Ohio-723, 2022 Ohio App. LEXIS 645 (6th Dist. Mar. 11, 2022).*
Plaintiff’s false arrest claims were time barred when they were filed. Heck does not apply and does not extend the time for his claim. Bonelli v. Grand Canyon Univ., 2022 U.S. App. LEXIS 6346 (9th Cir. Mar. 11, 2022).*
Stone bars Fourth Amendment claims in 2255 proceedings. United States v. Shade, 2022 U.S. Dist. LEXIS 43451 (S.D.Ohio Mar. 11, 2022).*