OH2: As to motel room registered guest, entry permitted by arrest warrant under Payton

If the person being sought is a registered guest in a motel room, Payton permits entry on an arrest warrant. If a guest, then a search warrant is required under Steagald. His car outside the room gave reason to believe he was there. A protective sweep of the room was also justified. State v. Chavez, 2018-Ohio-4351, 2018 Ohio App. LEXIS 4673 (2d Dist. Oct. 26, 2018).

Defendant was stopped with reasonable suspicion under Terry for driving back and forth in front of a residence. He was Mirandized and consented to a search of his cell phone. Yopp v. Commonwealth, 2018 Ky. App. LEXIS 259 (Oct. 26, 2018).*

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