United States v. Congo, No. 20-2184 (1st Cir. 2021)
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The First Circuit affirmed the district court's judgment denying Defendant's motion to suppress evidence obtained during the execution of a no-knock search warrant at the apartment where he and his girlfriend lived, holding that the district court did not err.
On appeal, Defendant argued that the district court erred by failing to suppress evidence obtained from the search of his backpack because his backpack was not properly subject to search and erred in failing to find that there was insufficient justification for the no-knock provision of the warrant. The First Circuit affirmed, holding (1) there was nothing improper about the search; and (2) the district court did not commit plain error by not ruling that the no-knock provision was unsupported.
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