OH4: In applying GFE, court isn’t bound by the “four corners” rule because Leon requires “all the circumstances” be considered

The affidavit for search warrant was lacking probable cause, but it wasn’t “so lacking” that the good faith exception did not apply. Also, the “four corners” rule doesn’t bar a trial court from considering “all the circumstances” in deciding whether the good faith exception applies. State v. Keefer, 2019-Ohio-2419, 2019 Ohio App. LEXIS 2528 (4th Dist. June 13, 2019).

“Here, the search warrant affidavit needed only to establish probable cause that evidence of the cited crimes, or property used to commit those crimes, would be found in a search of defendant’s cell phone. For the reasons explained below, even with the allegedly omitted facts added, the affidavit did so.” United States v. Razo-Quiroz, 2019 U.S. Dist. LEXIS 103706 (E.D. Cal. June 20, 2019).*

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