Defendant was a drug dealer, but the affidavit for warrant did nothing to show a reason to believe (nexus) that drugs would be found at his house. No case in this circuit supports nexus on these facts. Moreover, the information was so “scant” that the good faith exception would not be applied. United States v. Sanders, 2023 U.S. App. LEXIS 2859 (6th Cir. Feb. 6, 2023).
The interstate trucking inspection was reasonable and involved looking at safety equipment, log books, and cargo. The use of a drug dog during that stop did not extend it. United States v. Tu Anh Nguyen, 2023 U.S. App. LEXIS 3036 (8th Cir. Feb. 8, 2023).
Plaintiff had been arrested twice years apart on a warrant for another man with the same name but different identifiers. The second arrest was within the circuit’s reasonable mistake of fact jurisprudence, and he loses. He spent three days in jail the second time. No records were corrected or created to identify him as the wrong Sosa. Sosa v. Martin Cty., 2023 U.S. App. LEXIS 2861 (11th Cir. Feb. 6, 2023). [Apparently he is free to be arrested a third time.]