Defendant loaned his phone to another service member who accidentally discovered child pornography on it. The person the phone was loaned to had no common authority to consent to a search it. United States v. Black, 2022 CAAF LEXIS 614 (C.A.A.F. Aug. 25, 2022).
A motion to suppress filed at 11:59 pm Thursday before a Monday trial, seven months past the pretrial motions deadline, would not be considered. United States v. Blair, 2022 U.S. Dist. LEXIS 154406 (D. Neb. Aug. 27, 2022).*
Plaintiff’s § 1983 claim is a collateral attack against his conviction that is barred by the Eleventh Amendment and Heck v. Humphrey. Dismissed at screening stage. Stuart v. Lake Cty. Common Pleas Court, 2022 U.S. Dist. LEXIS 154504 (N.D. Ohio Aug. 26, 2022).*