Boilerplate language alone in an affidavit for warrant does not establish nexus. State v. Bracy, 2022 Iowa Sup. LEXIS 29 (Mar. 18, 2022) (citing § 6.14 of Treatise (§ 3:13 of 3d ed.).
Omitting a CI’s criminal history from the affidavit for search warrant is not per se a Franks violation. It did include he was getting consideration in another case of his own. United States v. Delong, 2022 U.S. Dist. LEXIS 48429 (N.D.Ill. Mar. 18, 2022).
The officer did not unreasonably extend the stop here. The drugs were seen immediately in plain view. United States v. Amey, 2022 U.S. Dist. LEXIS 48702 (S.D.Ala. Mar. 18, 2022).*