Defendant left his house before the search warrant arrived. Under Bailey, he could not be stopped and searched away from the house. State v. Muldrow, 2017-Ohio-8839, 2017 Ohio App. LEXIS 5272 (10th Dist. Dec. 5, 2017).
There was reasonable suspicion that defendant was under the influence to continue the detention. While the officer did not note in his report that defendant had glassy bloodshot eyes, he testified to it, and the court credits that’s what happened. State v. Hamilton, 2017-Ohio-8826, 2017 Ohio App. LEXIS 5248 (5th Dist. Dec. 1, 2017).*