Ohio Revised Code

Ohio Rev. Code § 2933.33 (2026)

Search of premises for illegal manufacture of methamphetamine

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(A) If a law enforcement officer has probable cause to believe that particular premises are used for the illegal manufacture of methamphetamine, for the purpose of conducting a search of the premises without a warrant, the risk of explosion or fire from the illegal manufacture of methamphetamine causing injury to the public constitutes exigent circumstances and reasonable grounds to believe that there is an immediate need to protect the lives, or property, of the officer and other individuals in the vicinity of the illegal manufacture.

(B) As used in this section, "methamphetamine" has the same meaning as in section 2925.01 of the Revised Code.

Notes of Decisions
Cited in 22 cases, 2008–2019 · leading case: State v. White, 886 N.E.2d 904 (Ohio Ct. App. 9th Dist. 2008).
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State v. White, 886 N.E.2d 904 (Ohio Ct. App. 9th Dist. 2008). · cites it 5× “To the extent that the state’s assignment of error pertains to the trial court’s suppression of the fruits of the warrantless search of White’s house in the case against Barrett, it is sustained because of the application of the inevitable-discovery exception to the exclusionary…”
State v. Maust, 2016-Ohio-3171. · cites it 3× “{¶56} R.C. 2933.33(A) states: If a law enforcement officer has probable cause to believe that particular premises are used for the illegal manufacture of methamphetamine, for the purpose of conducting a search of the premises without a warrant, the risk of explosion or fire from…”
State v. Scoggins, 2017-Ohio-8989. · cites it 4× “33 which states: (A) If a law enforcement officer has probable cause to believe that particular premises are used for the illegal manufacture of methamphetamine, for the purpose of conducting a search of the premises without a warrant, the risk of explosion or fire from the…”
State v. Zerucha, 2016-Ohio-1300. · cites it 2× “{¶20} We note that the state cites R.C. 2933.33 as an independent justification for the officer’s ultimate seizure of the items in appellant’s apartment.”
State v. Link, 2016-Ohio-4597. · cites it 10× “Although we rely on the law in Pape, we note that the facts in that case involved a much more egregious situation than those in the instant case.”
State v. Craw, 2018-Ohio-1769. “See R.C. 2933.33(A) (“[T]he risk of explosion or fire from the illegal manufacture of methamphetamine causing injury to the public constitutes exigent circumstances and reasonable grounds to believe that there is an immediate need to protect the lives, or property, of the…”
State v. Davis, 2017-Ohio-7572, 96 N.E.3d 1280. · cites it 2× “{¶26} Once the officers observed a methamphetamine lab through the door, R.C. 2933.33 permitted warrantless entry.”
State v. David, 2017-Ohio-1102. · cites it 3× “In Link, the trial court found exigent circumstances, because of the possibility that a methamphetamine laboratory was being operated, pursuant to R.C. 2933.33(A). Link, supra, at ¶23 . As we observed: {¶45} “[R.”
State v. Thomason, 2017-Ohio-7447. “33(A), which provides: {¶14} If a law enforcement officer has probable cause to believe that particular premises are used for the illegal manufacture of methamphetamine, for the purpose of conducting a search of the premises without a warrant, the risk of explosion or fire from…”
State v. Secriskey, 2017-Ohio-4169. · cites it 3× “24222, 2009-Ohio-3007 , ¶ 26, citing R.C. 2933.33(A). “Probable cause, therefore, is not required for a warrantless entry if officers have a reasonable belief that [a] methamphetamine laboratory is being operated at a particular location.”
State v. Armbruster, 2013-Ohio-3119. · cites it 4× “R.C. 2933.33(A). “This Court has held that clandestine methamphetamine laboratories pose a per se danger to occupants, officers, and the community, and law enforcement officers need only a reasonable belief that a structure contains a methamphetamine laboratory to justify a…”
State v. Grasso, 2013-Ohio-1894. · cites it 2× “R.C. 2933.33(A) provides: If a law enforcement officer has probable cause to believe that particular premises are used for the illegal manufacture of methamphetamine, for the purpose of conducting a search of the premises without a warrant, the risk of explosion or fire from the…”
Show all 22 citing cases →
Ohio Rev. Code § 2933.33(A): 15 cases
State v. Maust, 2016-Ohio-3171. “{¶56} R.C. 2933.33(A) states: If a law enforcement officer has probable cause to believe that particular premises are used for the illegal manufacture of methamphetamine, for the purpose of conducting a search of the premises without a warrant, the risk of explosion or fire from…”
State v. Scoggins, 2017-Ohio-8989. “33 which states: (A) If a law enforcement officer has probable cause to believe that particular premises are used for the illegal manufacture of methamphetamine, for the purpose of conducting a search of the premises without a warrant, the risk of explosion or fire from the…”
State v. Craw, 2018-Ohio-1769. “See R.C. 2933.33(A) (“[T]he risk of explosion or fire from the illegal manufacture of methamphetamine causing injury to the public constitutes exigent circumstances and reasonable grounds to believe that there is an immediate need to protect the lives, or property, of the…”
State v. Link, 2016-Ohio-4597. “Although we rely on the law in Pape, we note that the facts in that case involved a much more egregious situation than those in the instant case.”
State v. David, 2017-Ohio-1102. “In Link, the trial court found exigent circumstances, because of the possibility that a methamphetamine laboratory was being operated, pursuant to R.C. 2933.33(A). Link, supra, at ¶23 . As we observed: {¶45} “[R.”
Ohio Rev. Code § 2933.33(B): 1 case
State v. Griffin, 2019-Ohio-37.
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