OH has two on exigency: meth lab and a burglary in progress

911 call of people inside a neighbor’s home with flashlights was at least reasonable suspicion of a burglary in process to justify a warrantless entry. State v. Head, 2017-Ohio-7473, 2017 Ohio App. LEXIS 3787 (5th Dist. Sept. 6, 2017).

The smell of a working methamphetamine lab in defendant’s motel room was exigency for police entry, so defense counsel wasn’t ineffective for not moving to suppress. State v. Thomason, 2017-Ohio-7447, 2017 Ohio App. LEXIS 3767 (11th Dist. Sept. 5, 2017).