In an action before the Board for Correction of Naval Records, the service member had to raise his Fourth Amendment claim before the agency or it is waived, which is what happened here. McPherson v. Del Toro, Sec’y of the Navy, 2022 U.S. App. LEXIS 8147 (D.C.Cir. Mar. 28, 2022) (unpublished order).
Officers lacked probable cause for an entry into a motel room to arrest defendant. The R&R is rejected, and the motion to suppress is granted. United States v. Mott, 2022 U.S. Dist. LEXIS 55809 (W.D.Va. Mar. 28, 2022),* R&R 2022 U.S. Dist. LEXIS 56150 (W.D.Va. Feb. 25, 2022).*
A search warrant that seeks evidence for violations of federal law then lists them is sufficient. United States v. Calloway, 2022 U.S. Dist. LEXIS 56231 (W.D.Pa. Mar. 28, 2022).*
Defendant’s Fourth Amendment claim was waived by his guilty plea, but he’d lose on the merits anyway. People v. Kimmons, 2022 IL App (2d) 180589, 2022 Ill. App. LEXIS 144 (Mar. 29, 2022).*