The e-mail search warrant in this case authorized the search of “any and all” e-mails. It was reasonable for the issuing magistrate to conclude that e-mails in the e-mail account predating the exchanges between a person answering an advertisement for a trade of minors for sex and the person who placed the ad might have contained evidence relating to solicitation of a minor. The search warrant was as specific as the circumstances and the nature of the activity under investigation permitted. Also, the facts did not suggest any evidence of “exploratory rummaging” in the e-mails. Also, the record did not indicate that the search method employed by the detective was unreasonable. State v. Shaskus, 2016-Ohio-7942, 2016 Ohio App. LEXIS 4815 (10th Dist. Nov. 29, 2016).
The trial court should have applied a five factor test on the voluntariness of defendant’s consent. The first two were discussed but the other three were. On the totality of the record, despite the lack of findings, the finding of consent is affirmed. State v. Beard, 2016-Ohio-7874, 2016 Ohio App. LEXIS 4822 (10th Dist. Nov. 22, 2016).*