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6 Ohio opinions name it 1 courts 2014–2026 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.
| Case | Followed | Cited |
|---|---|---|
State v. Mishlergreen1 sentence2026Because the defendant’s motion to suppress “is merely a procedural vehicle to ‘put the ball into play,’” Crim.R. 47 does not demand “excruciating detail.” Codeluppi at ¶ 13 ; accord Curry at ¶ 37, 40 ; State v. Mishler, 2024-Ohio-1085, ¶ 13 (9th Dist.). | 1 | 1 |
State v. Currygreen2 sentences2026Because the defendant’s motion to suppress “is merely a procedural vehicle to ‘put the ball into play,’” Crim.R. 47 does not demand “excruciating detail.” Codeluppi at ¶ 13 ; accord Curry at ¶ 37, 40 ; State v. Mishler, 2024-Ohio-1085, ¶ 13 (9th Dist.). 2026A defendant triggers this obligation by filing a motion to suppress that is sufficient, under Crim.R. 47, to “put the State on notice that it [must] prove the constitutionality of the warrantless search with an exception to the warrant requirement.” State v. Curry, 2025-Ohio-2083, ¶ 41 (1st Dist.); see Codeluppi at ¶ 13 ; see also Wallace at paragraphs one and two of the syllabus. {¶19} Fair notice is the goal and the lodestar of the Crim.R. 47 analysis. | 1 | 1 |
Payton v. New Yorkgreen1 sentence2016We disagree. {¶13} Generally, the Fourth Amendment prohibits the police from making a warrantless nonconsensual entry into a suspect’s home in order to make a felony arrest. 4 Payton v. New York, 445 U.S. 573, 588-589 (1980). | 1 | 1 |
Griffin v. Wisconsingreen2 sentences2014Id., 483 U.S. at 875 , 107 S.Ct. at 3169 (citations omitted). {¶26} The Court continued to explain the rationale for the warrantless search exception applicable to probationers as follows: “A warrant requirement would interfere to an appreciable degree with the probation system, setting up a magistrate rather than the probation officer as the judge of how close a supervision the probationer requires. 2014Id., 483 U.S. at 875 , 107 S.Ct. at 3169 (citations omitted). {¶26} The Court continued to explain the rationale for the warrantless search exception applicable to probationers as follows: “A warrant requirement would interfere to an appreciable degree with the probation system, setting up a magistrate rather than the probation officer as the judge of how close a supervision the probationer requires. | 1 | 1 |
State v. Bentongreen2 sentences2014Moreover, the delay inherent in obtaining a warrant would make it more difficult for probation officials to respond quickly to evidence of misconduct * * * an would reduce Delaware County, Case No. 13 CAA 04 0028 9 the deterrent effect that the possibility of expeditious searches would otherwise create * * *.” Id., 483 U.S. at 876 , 107 S.Ct. at 3170 . {¶27} Thus, the Griffin court concluded that warrantless searches of a probationer's home and other property satisfies the Fourth Amendment's requirement of reasonableness if the warrantless search is “conducted pursuant to a valid regulation go 2014Moreover, the delay inherent in obtaining a warrant would make it more difficult for probation officials to respond quickly to evidence of misconduct * * * an would reduce Delaware County, Case No. 13 CAA 04 0028 9 the deterrent effect that the possibility of expeditious searches would otherwise create * * *.” Id., 483 U.S. at 876 , 107 S.Ct. at 3170 . {¶27} Thus, the Griffin court concluded that warrantless searches of a probationer's home and other property satisfies the Fourth Amendment's requirement of reasonableness if the warrantless search is “conducted pursuant to a valid regulation go | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
United States v. Bershchanskygreen2 sentences2016In reaching this holding, the court distinguished Bershchansky from other cases “in which courts have held warrants valid despite erroneous address numbers * * *, [because] other information in the warrant (or the executing officers’ knowledge) strongly indicated a particular location other than the misidentified address.” Id. 2016“Indeed, Apartment No. 2 was the only apartment that the magistrate judge could have authorized because the warrant application submitted by [the police] referenced no other apartment and did not provide probable cause to search any other apartment.” Id. {¶19} Despite the scope of the warrant, the police in Bershchansky searched Apartment No. 1, and the court found that “they conducted a warrantless search in violation of the Fourth Amendment.” Id. | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
Carroll v. Carman
green
2 sentences2017Id. at 352 . {¶18} In State v. Young, the appellant argued that a Detective’s presence on the back patio without a warrant or a legitimate basis for a warrantless search was a violation of the Fourth Amendment to the United States Constitution because the back patio was part of the home’s curtilage. 12th Dist. 2017Id. at 352 . {¶ 18} In State v. Young, the appellant argued that a Detective's presence on the back patio without a warrant or a legitimate basis for a warrantless search was a violation of the Fourth Amendment to the United States Constitution because the back patio was part of the home's curtilage. 2015-Ohio-1347 , 31 N.E.3d 178 , ¶15. | 1 | 2017–2017 |
Adams v. Williams
green
1 sentence2015The purpose of such a limited search "is not intended to discover evidence of a crime, but to allow the officer to pursue his duties 'without fear of violence.' " Id. at ¶ 13, quoting Adams v. Williams, 407 U.S. 143 (1972). {¶ 19} The warrantless search exception in Terry was "expanded to protective searches of automobiles in Michigan v. Long." Cordell at ¶ 14. | 1 | 2015–2015 |
Morrissey v. Brewer
green
1 sentence2014Id., 483 U.S. at 875 , 107 S.Ct. at 3169 (citations omitted). {¶26} The Court continued to explain the rationale for the warrantless search exception applicable to probationers as follows: “A warrant requirement would interfere to an appreciable degree with the probation system, setting up a magistrate rather than the probation officer as the judge of how close a supervision the probationer requires. | 1 | 2014–2014 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.