The trial court suppressed but the court of appeals reversed. The supreme court granted discretionary review, but it was dismissed for defendant’s failure to file a brief. The case was remanded back to the trial court, and the appellate reversal was law of the case where discretionary review was dismissed. State v. Clayton, 2017-Ohio-8538, 2017 Ohio App. LEXIS 4951 (12th Dist. Nov. 13, 2017).
Investigating a burglary, the officer found the defendant with a baggie of marijuana sticking out of his pocket. That was a valid plain view. State v. Smith, 2017-Ohio-8558, 2017 Ohio App. LEXIS 4968 (1st Dist. Nov. 15, 2017).*