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).*