OH9: Inadequate findings on officer safety patdown requires remand

The trial court’s findings of an alleged officer safety justification for his patdown are inadequate for the court of appeals to decide whether the state justified the patdown. Remanded for more findings. State v. Murphy, 2019-Ohio-515, 2019 Ohio App. LEXIS 523 (9th Dist. Feb. 13, 2019).*

Two courts cannot exercise jurisdiction over property subject to forfeiture. Defendant should have filed a motion for return of property in the criminal case. But, when the federal government assumed jurisdiction over the forfeiture, the state court lost jurisdiction. Jenkins v. City of Cleveland, 2019-Ohio-458, 2019 Ohio App. LEXIS 492 (8th Dist. Feb. 12, 2019).*

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