ME: State constitutional arguments must be developed; citing it not enough

(1) The tracking device placed on defendant’s vehicle by court order was with probable cause. (2) “For a claim under the Maine Constitution to be deemed preserved for our review, however, the party advancing the claim cannot merely allude to or cite the Maine Constitution but must develop his argument.” “What is required to preserve a state constitutional claim will vary by context.” (3) Finally, “The special agent’s failure to fulfill multiple requirements of M.R.U. Crim. P. 41(g) [on return and inventory], though ‘subject to strong disapproval,’ does not require that the evidence be suppressed.” State v. Norris, 2023 ME 60, 2023 Me. LEXIS 70 (Aug. 31, 2023).

Successor habeas petitioner’s Fourth Amendment ineffective assistance of counsel claim that his DNA was illegally taken was relitigating the same issue in his 2254. “Because Ragland’s claims in his current application are identical to the claims in his original petition, we lack jurisdiction to consider them.” In re Ragland, 2023 U.S. App. LEXIS 23241 (11th Cir. Aug. 31, 2023).*

“So, in the Fourth Amendment context, a seizure arises if a police officer intentionally causes a crash to end a police chase whereas no seizure occurs if there is simply an accidental crash. The officers have offered no reason the same would not be true under the Fourteenth Amendment.” Cheeks v. Belmar, 2023 U.S. App. LEXIS 23264 (8th Cir. Sep. 1, 2023).*