N.D.Ohio: Sitting alone on porch doesn’t justify a protective sweep; but consent was still valid

The protective sweep here was invalid: “Here, the officers had no articulable basis to believe that anyone was in King’s house as King sat on the front porch.” However, his later consent search was valid. “Defendant claims that he did not voluntarily give his consent to the home search because an officer had threatened to obtain a warrant to search his home if Defendant did not consent. Although an officer’s baseless threat to obtain a warrant may render a consent involuntary, the threat here was a stretch but was not completely baseless.” United States v. King, 2019 U.S. Dist. LEXIS 72013 (N.D. Ohio Apr. 27, 2019).