N.D.Ohio: Controlled buy is PC; CI’s alleged lie isn’t Franks issue

A controlled buy was probable cause. The claim that the CI lied isn’t cognizable under Franks. United States v. Sheridan, 2020 U.S. Dist. LEXIS 36163 (N.D. Ohio. Mar. 3, 2020).

There were disputed questions of fact on whether it was necessary for the officer to shoot at a passing car, so there was no basis for appeal. Gallmon v. Cooper, 2020 U.S. App. LEXIS 6696 (4th Cir. Mar. 3, 2020).*

The frisk of defendant’s fannypack was reasonable under Terry because of a police BOLO and he matched the description of a robber and a call from another officer about him. Search of the fannypack was also valid by inevitable discovery on his arrest. United States v. Cherry, 2020 U.S. Dist. LEXIS 36145 (N.D. Ga. Mar. 3, 2020).*