OH6: Def doesn’t have standing to challenge search of another that led to PC for his SW

Defendant claimed that part of the facts of probable cause in the affidavit for his search warrant shouldn’t have been considered because of an illegal search of another. He doesn’t have standing to contest that search, and it can be considered. State v. Middlebrooks, 2019-Ohio-2149, 2019 Ohio App. LEXIS 2216 (6th Dist. May 31, 2019).

CSLI had been obtained in 2015 for defendant’s cell phone, and it was admissible and wouldn’t be excluded even though Carpenter came by the time of trial. State v. Jones, 2019-Ohio-2134, 2019 Ohio App. LEXIS 2220 (10th Dist. May 30, 2019).*