D.Neb.: State officer’s jurisdiction is not a 4A question

State officers outside their jurisdiction making an arrest is not alone a Fourth Amendment violation. Virginia v. Moore. United States v. Blair, 2022 U.S. Dist. LEXIS 47833 (D.Neb. Mar. 17, 2022).*

Defendant found to have consented to a search after being Mirandized. United States v. Demons, 2022 U.S. Dist. LEXIS 47929 (N.D.Ga. Mar. 17, 2022).*

Plaintiff’s § 1983 claim of false arrest and illegal search during the pendency of his criminal case is stayed pending resolution of the state case. Howard v. Kamimer, 2022 U.S. Dist. LEXIS 47818 (S.D.Ga. Feb. 16, 2022).*

Defendant’s Fourth Amendment claim on appeal was not adequately presented to the trial court. (Dissent: It was. The trial court’s ruling was “stream of consciousness,” and defense counsel sought clarification, and the trial court said he got it.) State v. Tower, 2022 Ida. LEXIS 34 (Mar. 17, 2022).*

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