OH: At the time the GPS was installed, SCOTUS authority at least “suggested” in Knotts and Karo that it was constitutional, and that’s good enough for government work

At the time the GPS was put on defendant’s car, SCOTUS authority at least “suggested” in Knotts and Karo, before GPS was even envisioned, that it was constitutional, and that’s good enough for government work. The Davis good faith exception thus applied [even though state not relying on any specific authority that was reversed, as was in Davis]. State v. Johnson, 2014-Ohio-5021, 2014 Ohio LEXIS 2918 (November 13, 2014).

Asleep in one’s car on the shoulder of an interstate about 1 am with a strong odor of intoxicants is reasonable suspicion. State v. Koss, 2014-Ohio-5042, 2014 Ohio App. LEXIS 4899 (10th Dist. November 13, 2014).*