S.D.N.Y.: Pending recalculation of time on parole didn’t affect legality of parole search

Defendant’s state remaining parole time was subjected to recalculation but it hadn’t happened by the time of the parole search based on a tip he had a firearm. Therefore it was reasonable. Alternatively, it was by consent. United States v. Brown, 2023 U.S. Dist. LEXIS 7279 (S.D.N.Y. Jan. 13, 2023).*

Defendant’s evasions before being finally stopped justified his frisk when he was finally stopped and handcuffed. State v. Abrams, 2023-NCCOA-12, 2023 N.C. App. LEXIS 16 (Jan. 17, 2023).*

Defendant doesn’t get to withdraw his plea because of an alleged Franks violation where there was not shown falsity to undermine probable cause. United States v. Lillard, 2023 U.S. App. LEXIS 978 (9th Cir. Jan. 17, 2023).*

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