The probation search of defendant’s house was valid. The probation officer was acting on a tip that defendant had a meth lab in the house. Task force officers aided in the search. No meth lab was found, so the PO requested a task force officer to search a dresser and drugs were found. The probation search was valid. State v. Muhlenkamp, 2017-Ohio-8269, 2017 Ohio App. LEXIS 4654 (3d Dist. Oct. 23, 2017).
There is no Miranda requirement before a consent search is sought of a person not in custody. State v. Casteel, 2017-Ohio-8303, 2017 Ohio App. LEXIS 4678 (4th Dist. Oct. 18, 2017).