OH9: Def’s innocent explanations don’t per se undermine reasonable suspicion

Defendant’s innocent explanations for being in the parking lot in a high crime area don’t undermine the officer’s reasonable suspicion developed at the time. State v. Starr, 2015-Ohio-2193, 2015 Ohio App. LEXIS 2113 (9th Dist. June 8, 2015).*

The probation search condition here required probable cause, and it was lacking, so the motion to suppress is granted. The state does not need probable cause, but that was in the conditions that defendant consented to. State v. Vanderkolk, 2015 Ind. LEXIS 507 (June 9, 2015).*

Defendant had no standing to contest the search of the parking lot he was found in where a gun was located. People v. Ested, 2015 NY Slip Op 04861, 2015 N.Y. App. Div. LEXIS 4770 (2d Dept. June 10, 2015).*