A probation officer at defendant’s house for a home visit could smell around the door, and, here, the smell of marijuana being used inside was evident. That was not unreasonable. United States v. Toney, 2022 U.S. Dist. LEXIS 120895 (E.D. Ark. July 8, 2022).
The CI here was known and in custody, and his information was significantly corroborated before the warrant was sought, so probable cause was shown. United States v. Powell, 2022 U.S. App. LEXIS 18862 (6th Cir. July 8, 2022).*
Defendant cannot show ineffectiveness on a Playpen warrant issue where the good faith exception has always been applied to them. United States v. Keith, 2022 U.S. Dist. LEXIS 120986 (S.D.N.Y. July 8, 2022).*