Defendant was arrested in 2016 for a murder. He raised a CSLI issue, and he was tried after Carpenter was decided. He gets the benefit of Carpenter because his case was still pending when it came down. Nevertheless, there was exigency and that exception applies. State v. Snowden, 2019-Ohio-3006, 2019 Ohio App. LEXIS 3096 (2d Dist. July 26, 2019).
Defendant was frisked, and in the watch pocket, it was immediately apparent to the officer, a former jailer who’d searched thousands, that a small baggie of drugs was there by its feel. Removing it was reasonable. State v. Oliver, 2019-Ohio-3007, 2019 Ohio App. LEXIS 3097 (5th Dist. July 24, 2019).*