OH12: Package in transit was reasonably briefly detained for dog sniff

Briefly detaining a package in transit at least on reasonable suspicion for a dog sniff was reasonable and not a seizure of the package. They were staying at a local B&B and received two FedEx packages there, one under an assumed name, which was suspicious in itself. State v. Valenzuela-Pena, 2019-Ohio-1701, 2019 Ohio App. LEXIS 1789 (12th Dist. May 6, 2019).

Defendant’s 2254 that DNA couldn’t be taken from his victim’s baby was denied in the state courts on the merits for lack of standing. Therefore, it’s barred in a 2254 by Stone v. Powell. Hannan v. Ryan, 2019 U.S. Dist. LEXIS 77027 (D. Ariz. May 6, 2019).*

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