OH7: Wooded area behind house was open fields, not curtilage

The area where defendant’s grow operation was found was not curtilage. It was a long distance from the house in a wooded area, and it was in “open fields.” State v. Hambleton, 2017-Ohio-7561, 2017 Ohio App. LEXIS 3876 (7th Dist. Sept. 11, 2017).

Defendant challenged a consent to seize and search clothing for murder victim’s blood at the police station issued under the threat to get a search warrant. Actually, the search warrant was in the process of being issued, and it was. The search is valid under the warrant. State v. Lepon, 2017 Iowa App. LEXIS 886 (Sept. 13, 2017).*

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