What is the basis for a finding of false statements in an affidavit?

MultiRegion, United States of America

The following excerpt is from U.S. v. Barrett, 967 F.2d 592 (9th Cir. 1992):

Later the court noted "if you read her statement, you'll see several references to her mom's house." There was no patently false statement in the affidavit, and no evidentiary hearing pursuant to Franks v. Delaware, 438 U.S. 154 (1978), was required. See McQuisten, 795 F.2d at 862-63.

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