NY2: Franks claim has to be fully developed; it’s more than just a false statement

Franks claim fails for failure to show how the alleged false statements undermined the probable cause. “The defendant failed to meet his burden of controverting the warrant, as he failed to analyze, must less establish, that after the excise of allegedly offending statements in the officer’s affidavit, the remaining content was insufficient to establish probable cause.” People v. Biggs, 2022 NY Slip Op 05328, 2022 N.Y. App. Div. LEXIS 5226 (2d Dept. Sep. 28, 2022).

The anonymous tip here wasn’t able to be corroborated in its suggestion of crime, and thus lacked reasonable suspicion. State v. Barclift, 2022 ME 50, 2022 Me. LEXIS 52 (Sep. 27, 2022).

Defendant’s stop after a “disturbance” call was with reasonable suspicion. Coleman v. State, 2022 Ind. App. LEXIS 321 (Sep. 29, 2022).*

There was reasonable suspicion for defendant’s stop, and his failure to identify himself was probable cause of obstruction. The search incident that followed was reasonable. State v. Hargrove, 2022 La. App. LEXIS 1683 (La. App. 3 Cir. Sep. 28, 2022).*

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