The state’s inventory argument was not presented during the suppression hearing, and it can’t rely on that argument on appeal. State v. Steele, 290 Ore. App. 675, 2018 Ore. App. LEXIS 41 (Mar. 7, 2018).
By letting the CI into his home for a drug buy, the defendant consented to the entry and it did not violate the Fourth Amendment or the state constitution. State v. Powell, 2018-Ohio-1276, 2018 Ohio App. LEXIS 1400 (4th Dist. Apr. 3, 2018).