United States v. Geraldo, Jose

Opinion for the Court filed by Circuit Judge RANDOLPH.

RANDOLPH, Circuit Judge:

Searches carried out by federal agents at two District of Columbia residences— one at 1430 Newton Street, the other at 1823 Newton Street — led to the arrest, indictment and conviction of Jose Geraldo. In this appeal Geraldo claims the 1430 Newton Street search violated the federal knock and announce statute, 18 U.S.C. § 3109, and exceeded the scope of the search warrant. As to 1823 Newton Street, he maintains that his trial counsel was constitutionally ineffective because he did not assert Geraldo’s privacy…