OH5: Meth lab was in a building not on the curtilage

The meth lab on defendant’s property was not on the curtilage. It was a separate building away from the house. State v. Schorr, 2014-Ohio-2992, 2014 Ohio App. LEXIS 2933 (5th Dist. July 2, 2014).*

The officer here was justified in getting defendant out of the vehicle and patting him down because of him stuffing something in his pants. State v. Moore, 2014-Ohio-2979, 2014 Ohio App. LEXIS 2917 (8th Dist. July 3, 2014).*

The protective sweep here was valid because the police knew defendant was in the company of another person who could have been inside the house. United States v. Shegonee, 2014 U.S. Dist. LEXIS 92402 (E.D. Wis. April 25, 2014).*