CA7: Prima facie Franks violation made not disclosing CI’s motives; remanded

Defendant made his prima facie case of a Franks violation, and he was entitled to a hearing. The informants were involved in a love quadrangle not revealed to the warrant issuing judge. Analyzing the affidavit sentence by sentence, the omissions are glaring and troubling. United States v. Taylor, 2023 U.S. App. LEXIS 7136 (7th Cir. Mar. 24, 2023) (this case is informative on how de novo review of a Franks violation should work).

Lifetime electronic monitoring wasn’t raised below as an unreasonable search, and it’s not plain error. People v. Casey, 2023 Mich. App. LEXIS 2054 (Mar. 23, 2023).*

Defendant didn’t challenge the OVI checkpoint. He had no DL, and things went downhill from there. No suppression. State v. Whitten, 2023-Ohio-973 (6th Dist. Mar. 24, 2023).*

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