CA8: Hotel staff photographed evidence of drug use in room which corroborated CI

The information in the search warrant application was sufficient to show a fair probability that contraband or evidence of a crime would be found in a hotel room registered to a known drug user who had recently tested positive for drugs, and the hotel staff had found evidence of drug use in the room that day which they photographed. Also, the application was not stale. Finally, the police corroborated the confidential informant’s information and the photographs by the hotel staff provided good reason to believe the informant was truthful. United States v. Salsberry, 2019 U.S. App. LEXIS 17394 (8th Cir. June 11, 2019).*

The trial court’s order is reversed for lack of adequate findings for appellate review. State v. Thompson, 2019-Ohio-2269, 2019 Ohio App. LEXIS 2362 (9th Dist. June 10, 2019).*

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