Exigent circumstances exception permitting warrantless search of a home when police reasonably believe criminal evidence is being destroyed within applies even though the police’s lawful knock and announce at the house door is what prompts the inhabitants to destroy the evidence.

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Under the Sixth Amendment Strickland standard for effective assistance of counsel, “constitutionally competent counsel would have advised [the defendant] that his conviction for drug distribution made him subject to automatic deportation.”

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Police may search a vehicle incident to a recent occupant’s arrest only if the arrestee is within reaching distance of the passenger compartment at the time of the search or it is reasonable to believe the vehicle contains evidence of the offense of arrest.

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