OH5: ‘Blading’ one’s body alone is not enough for RS

“[V]irtually the only suspicious activity the officer articulated was ‘blading’ his body away from the officer’s view. We find this testimony insufficient to conclude the stop of appellant was proper.” State v. Caplinger, 2013-Ohio-5675, 2013 Ohio App. LEXIS 5940 (5th Dist. December 10, 2013).*

Pre-Jones GPS tracking will not be excluded under Davis. Indeed, in this case, the defense at first conceded it was valid under circuit precedent and didn’t pursue the argument until Jones came down. United States v. Smith, 741 F.3d 1211 (11th Cir. 2013).

Probable cause for the search warrant of defendant’s property was shown based on the product of wiretaps and then three CIs who were corroborated. United States v. Boon, 2013 U.S. Dist. LEXIS 179674 (W.D. N.Y. December 12, 2013).*