Where a recording of defendant was made in California in violation of California law but being used in a prosecution in Ohio, the exclusionary rule would not be applied. The recording violated neither the Fourth Amendment nor Ohio law, and it was otherwise admissible. State v. Knoefel, 2015-Ohio-5207, 2015 Ohio App. LEXIS 5043 (11th Dist. Dec. 14, 2015).
Where decedent fired at police first, shooting back was reasonable under the Fourth Amendment. Howard v. City of Pine Bluff, 2015 U.S. Dist. LEXIS 166903 (E.D.Ark. Dec. 14, 2015).*