OH7: Enclosed porch door was curtilage, but inside door was threshold door

Defendant’s house had an unlocked porch door and a door inside. The porch door was part of the curtilage, but it was reasonable for persons visiting to go to the inside door and knock. “Based on this record, the facts and circumstances demonstrate that it was reasonable for the officers to believe that the interior door was the threshold door.” Once inside, the record demonstrated that the defendant consented to a search of the premises rather than have the premises effectively seized for a search warrant to be obtained. [Officers observed enough to have probable cause.] State v. Green, 2017-Ohio-7757, 2017 Ohio App. LEXIS 4103 (7th Dist. Sept. 18, 2017).

Defendant’s speeding, demeanor and appearance, and admission he’d consumed alcohol was reasonable suspicion. State v. Adams, 2017-Ohio-7743, 2017 Ohio App. LEXIS 4077 (2d Dist. Sept. 22, 2017).*