OH11: Officer’s delay in investigation of defendant made pursuit no longer “hot pursuit”

The officer had probable cause for defendant’s arrest, but it wasn’t any longer hot pursuit because the officer directed his attention elsewhere. The entry into defendant’s house could not be justified by hot pursuit. State v. Lowe, 2015-Ohio-1064, 2015 Ohio App. LEXIS 1036 (11th Dist. March 23, 2015).

Seizure of animals was a provisional remedy not yet appealable under Ohio law. State v. Beck, 2015-Ohio-1069, 2015 Ohio App. LEXIS 1020 (11th Dist. March 23, 2015).*

Defendant’s argument that his blood draw was done by an “unauthorized person,” a registered nurse for 52 years who was an “authorized person” was meritless. State v. Waldock, 2015-Ohio-1079, 2015 Ohio App. LEXIS 994 (3d Dist. March 23, 2015).*