Leon analysis (Ohio) · Go Syfert
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Leon analysis in Ohio

6 Ohio opinions name it 2 courts 1989–2022 1 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

CaseFollowedCited
United States v. Leongreen
scotus · 1984 · cited in 3 Ohio opinions naming this issue, 2003–2020
2 sentences

2020Id. {¶ 73} The state’s argument does not align with Leon’s analysis of the third exception.

2019See Leon, supra, 468 U.S., at 916–922, 104 S.Ct. at 3417–3420; Sheppard, supra, 468 U.S., at 990–991, 104 S.Ct. at 3428–3429.

13
United States v. Tyrone Christiangreen
ca6 · 2019 · cited in 1 Ohio opinions naming this issue, 2022–2022
1 sentence

2022The majority conflates an affidavit that is bare bones with an affidavit that lacks probable cause {¶ 49} “Too often courts raise the Leon bar, making it practically indistinguishable from the probable cause standard itself.” Christian, 925 F.3d at 318 (Thapar, J., concurring).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
State v. Wilmoth green
ohio · 1986
2 sentences

2020We adopted the Leon analysis in State v. Wilmoth, 22 Ohio St.3d 251 , 490 N.E.2d 1236 (1986).

2020We adopted the Leon analysis in State v. Wilmoth, 22 Ohio St.3d 251 , 490 N.E.2d 1236 (1986).

21989–2020
United States v. Tyrone Gilbert green
ca6 · 2020
1 sentence

2022This is what the majority has done in concluding that 24 January Term, 2022 the affidavit at issue is bare bones; it has “confuse[d] a bare bones affidavit with one that merely lacks probable cause,” Gilbert, 952 F.3d at 763 . {¶ 50} The majority ignores the verifiable facts in the affidavit, which establish “some connection” between the fatal automobile accident and the cell phones found at the accident scene.

12022–2022
United States v. Gary Lynn Weaver green
ca6 · 1998
1 sentence

2008Therefore, we do not apply these cases to our Leon analysis. {¶ 38} The defense also relies on United States v. Weaver (C.A.6, 1996), 99 F.3d 1372 , to argue that the affidavit lacked indicia of probable cause.

12008–2008

Where else courts name it

CA 28 (1988–2024) IL 12 (1994–2022) VA 10 (1991–2008) IN 10 (1988–2007) LA 9 (1985–2010) KS 7 (1985–2025) MD 7 (1994–2024) GA 7 (1999–2023) FL 7 (1989–2024) NJ 6 (1985–2015) OH 6 (1989–2022) AL 5 (1990–2012) CO 5 (1985–2003) TX 5 (1993–2018) AZ 5 (1967–2017) IA 4 (1992–2025) WI 3 (2000–2019) PA 3 (1991–2024) AR 3 (1987–2007) UT 3 (1987–1991) OK 2 (2018–2018) ND 2 (1989–1990) NE 2 (1999–2005) NV 2 (2002–2003) NM 2 (1991–1993) SD 2 (2000–2004)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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