The state’s plain view argument wasn’t pressed in the trial court, so it can’t be a basis for appeal. Even on the merits, the state loses because the stop was invalid, and the detention unreasonable all before the alleged plain view. State v. McQueen, 2018-Ohio-3996, 2018 Ohio App. LEXIS 4323 (8th Dist. Oct. 1, 2018).
Late disclosure of a jail call didn’t prejudice the defendant in light of the overwhelming proof at trial. State v. Cummings, 2018-Ohio-3993, 2018 Ohio App. LEXIS 4322 (8th Dist. Oct. 1, 2018).*