OH8: New information added to older information overcame staleness objection

Three months between seizure of defendant’s cell phone and search of his house based on the product of the first seizure wasn’t stale. Defendant was in a gang that recorded their crimes and uploaded them by phone to social media, and that made the phones relevant to a shooting. State v. Shropshire, 2016-Ohio-7224, 2016 Ohio App. LEXIS 4087 (8th Dist. Oct. 6, 2016):

[*P27] We find that although three months had passed between the time the police seized Shropshire’s phone and the time the search warrant for his house was issued, the information contained in the search warrant was not stale. Detective Vertosnik explained that Shropshire was the lead suspect in Hamilton’s shooting, the police had recovered photos of guns from Shropshire’s phone, Shropshire was a known gang member, the police had previously linked Shropshire to having weapons at his house, and gang members often kept firearms after committing crimes with them rather then disposing of them.