OH9: Thermal imaging SW lacked PC when only electrical usage was mentioned

The thermal imaging search warrant was bare bones and did not support probable cause or application of the good faith exception. Electrical usage alone was not enough: “No additional information or data regarding the properties or their electricity usage is included within the affidavit.” State v. Henderson, 2019-Ohio-1974, 2019 Ohio App. LEXIS 2046 (9th Dist. May 22, 2019).

While the affidavit for the search warrant omitted a reference to time, there was a trash pull just before the warrant application. That supports applying the good faith exception. United States v. Jordan, 2019 U.S. App. LEXIS 15142 (4th Cir. May 22, 2019).*

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