D.Ore.: FISA’s “significant purpose” requirement satisfies Fourth Amendment

FISA’s “significant purpose” requirement has been upheld by several circuits under the Fourth Amendment. The PATRIOT Act amendments have also been upheld. This court doesn’t disagree. United States v. Mohamud, 2012 U.S. Dist. LEXIS 186093 (D. Ore. May 7, 2012).*

A commercial building that was the subject of an arson was reasonably searched under Tyler and Clifford. The owner’s interest is less in a commercial property than in a home. No effort had been made to secure the property after the fire. United States v. Cromer, 2012 U.S. Dist. LEXIS 186153 (E.D. Mo. July 11, 2012).*

2255 petitioner “supplies a laundry list of criticisms relating to his counsel’s pretrial investigation and management of a motion to suppress” that was litigated and lost, and then petitioner pled guilty. That was a waiver. Petitioner claims defense counsel didn’t address the Fourth Amendment in the motion to suppress, but he clearly and effectively did. “Counsel was not ineffective merely because the Court ruled against him on the motion.” Leggette v. United States, 2013 U.S. Dist. LEXIS 21569 (S.D. W.Va. January 7, 2013).*