Third Circuit -- USA v. Paul Pavulak

Affidavit wasn't specific enough to justify the warrant, but police relied in good faith.  Where the same officer who obtained the affidavit conducted the search, not a per se violation.

No error in denial of Franks hearing, as deft didn't make sufficient showing.

No error in Prsc's closing - "consider the big picture" not improper cumulaiton.

Sufficient evidence for conviction.

No error in court applying modified categorical analysis for sentencing to impose mandatory life sentence, as statutory maximum would otherwise be life -- Apprendi is not triggered.

USA v. Paul Pavulak