OH7: No REP in a police interrogation room where def was left with wife with recorder on

There is no reasonable expectation of privacy in a police interrogation room where defendant was left and was recorded talking to his wife about the shooting. State v. Paige, 2019-Ohio-1088, 2019 Ohio App. LEXIS 1162 (7th Dist. Mar. 27, 2019)

“The evidence indicated that he stopped it for about one minute while the officer entered the license plate in a computer. But considering the totality of the circumstances, Defendant never manifested submission to the implied directive to speak to the officer, and he was thus never effectively seized.” And, “[b]ased on the totality of the circumstances, the court concludes Sgt. Mitchell had a particularized and objective basis to suspect that the occupants of the pickup truck were involved in criminal activity, such that a brief investigative detention was warranted.” United States v. Silcott, 2019 U.S. Dist. LEXIS 51499 (D. Kan. Mar. 27, 2019).*