OH3: Citizen informant reliable per se; dispatcher doesn’t need to be called at suppression hearing

“Unlike Navarette, this case presents an identified citizen informant, who, according to Weisner, is credited with greater reliability.” It also wasn’t necessary to call the police dispatcher at the suppression hearing. State v. Hancock, 2016-Ohio-2671, 2016 Ohio App. LEXIS 1544 (3d Dist. April 25, 2016).

Defendant’s actions individually were not suggestive of criminality, but collectively they were and that’s reasonable suspicion. State v. Hair, 2016-Ohio-2679, 2016 Ohio App. LEXIS 1549 (12th Dist. April 25, 2016).*

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