During a fire in a house, a grow operation was seen and reported to the police. By the time the police came in, the fire was out, the power was off, and the property was secure. The warrantless fire scene search was unreasonable because there no longer was any exigency. State v. Smith, 2018-Ohio-3436, 2018 Ohio App. LEXIS 3724 (5th Dist. Aug. 24, 2018).
The identified victim of a crime is not treated the same as a CI for probable cause. United States v. Serrano-Ramirez, 2018 U.S. Dist. LEXIS 146401 (M.D. Tenn. Aug. 28, 2018).*