The defendant was not entitled to Franks hearing.

U.S. v. Valencia-Trujillo, 2009 WL 1929157 (11th Cir. July 7, 2009)

The defendant was convicted of several drug and money laundering crimes after being extradicted to the U.S. from Colombia in 2002. He was sentenced to 480 months imprisonment and to forfeit $110 million.  The Fourth Amendment does not apply to actions against foreign citizens on foreign soil. The Supreme Court has explained that a violation of the fourth Amendment is ‘fully accomplished’ at the time of an unreasonable governmental intrusion.

The case did not warrant reversal.

The Court of Appeals stated that the defendant points out that he put into evidence handwritten notes identifying the owners of the cocaine aboard both vessels and that he was not one of them. Yet other evidence existed from which the jury could find defendant responsible for the cocaine aboard those vessels. And, again, there were three other predicate acts anyway.

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