Defendant’s arrest in Texas on a Michigan warrant shown on NCIC was reasonable under the Fourth Amendment despite the claim that it was not flagged for out-of-state extradition. Six months earlier, he was arrested and released before getting to jail on the same warrant. United States v. Shaughnessy, 2023 U.S. Dist. LEXIS 77817 (N.D. Tex. May 4, 2023).
Petitioner filed a motion to suppress in state court that defense counsel did not adopt because it was defective. Still, he had a full and fair opportunity to litigate it there and Stone bars relief. Also, defense counsel wasn’t ineffective. Carr v. Goodwin, 2023 U.S. Dist. LEXIS 77645 (W.D. La. Apr. 3, 2023).*
Carpenter on remand still: First Step Act not applied. United States v. Carpenter, 2023 U.S. App. LEXIS 10963 (6th Cir. May 2, 2023).*