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LA3: Not mentioning that CI was defendant's girlfriend with a revenge motive did not violate Franks

By John Wesley Hall, Jr.

It was not a Franks violation to fail to include that the informant was defendant's former girlfriend with a motive to do him in. That did not undercut the showing of probable cause. State v. Bayonne, 2008 La. App. LEXIS 1425 (3d Cir. November 5, 2008).* Probable cause was shown for defendant's blood test based on a showing he was likely under the influence. Combs v. State, 2008 Ind. App. LEXIS 2499 (November 5, 2008).* New crime during an illegal arrest will not be suppressed. State v. Newbern, 2008 Ohio 5712, 2008 Ohio App. LEXIS 4802 (5th Dist. November 4, 2008).*

Full post as published by Fourth Amendment on November 10, 2008 (boomark / email).