OH5: Def’s wrecked empty car on road to house justified entry onto curtilage to check on potential injury

Defendant’s car was upside down and there was blood on the passenger air bag. Nobody was there. The officer went to the house where the car was registered to find the driver and passenger. “Present in this case was a very badly damaged vehicle containing blood on the passenger side airbag with no occupants present at the scene. The address chosen to locate appellant was the address closest to the scene and in the same direction that the vehicle was headed. We find these facts justify further investigation at the Syler Road address in an attempt to locate a driver or passengers who could have been involved in the crash and injured. The knocking at the doors was clearly within the spectrum of an auto accident investigation with the issue of possible injury.” This didn’t violate the curtilage because of exigency and produced the smell of marijuana. State v. Doyle, 2016-Ohio-5742, 2016 Ohio App. LEXIS 3615 (5th Dist. Aug. 29, 2016).*

Officers had probable cause to believe there was a working meth lab in a car based on CI information and corroboration of that and other background information and defendant’s drug history. State v. Runyon, 2016-Ohio-5730, 2016 Ohio App. LEXIS 3638 (2d Dist. Sept. 9, 2016).*