From John Grasso

Members -

Here is an interesting 1st Circuit Opinion that discusses Franks Hearings in some detail with particular emphasis on the duty of law enforcement to investigate further and whether its failure to investigate further is reckless. “Our holding is that the district court erred in ruling as a matter of law that an affiant never has a duty to make further inquiry before presenting a warrant application to a magistrate.”

http://media.ca1.uscourts.gov/pdf.opinions/14-1174P-01A.pdf