OH4: Def’s coming to site of execution of SW and then hanging around next door justified a detention and frisk

Defendant came to the site of execution of a search warrant and was justifiably detained. “First, the court found that Deputy Robison was justified as part of his efforts to secure a safe search site because Collins arrived on the property during the search and then stayed in the vicinity, parked on the neighboring property. The trial court found that Collins’s position on the neighboring property was close enough to the search site to pose a safety concern for the officers. See Michigan v. Summers, … as limited by Bailey v. United States, …. Second, after talking with Collins and the neighbors on whose property Collins was parked, Deputy Robison had reasonable suspicion that Collins was engaged in criminal trespassing, which provided a separate justification for his stop and pat-down of Collins. See Terry v. Ohio, ….” State v. Collins, 2019-Ohio-1724, 2019 Ohio App. LEXIS 1806 (4th Dist. Apr. 25, 2019).

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