Officers entered the home on an arrest warrant and consent. Inside, they saw a gun case. A search of a small closed container in the gun case was reasonable incident to arrest. If it was in a dresser drawer or elsewhere in the house, not so. United States v. Smith, 2022 U.S. Dist. LEXIS 133728 (N.D. Ohio July 27, 2022).
Pole camera surveillance of both front and back of defendant’s home was reasonable. United States v. Dennis, 2022 U.S. App. LEXIS 20807 (5th Cir. July 27, 2022).
The traffic stop was diligently pursued and not delayed. United States v. Garrett, 2022 U.S. App. LEXIS 20846 (2d Cir. July 28, 2022).*
In an IAC claim for failure to challenge entry onto the curtilage, the case is remanded to the district court for additional findings on whether the curtilage was violated and the prejudice from failure to challenge it. Chong v. United States, 2022 U.S. App. LEXIS 20838 (9th Cir. July 27, 2022).*