The search warrant referred to the premises to be searched as “5243/45 Broadway.” It was one continuous apartment downstairs with one address, and the other upstairs was still being built and was occupied. 5243 was used on the search warrant because it was the only address visible on the building. The warrant applied to the entire multi-unit building, and it was valid. State v. Payne, 2019-Ohio-4158, 2019 Ohio App. LEXIS 4236 (8th Dist. Oct. 10, 2019).
In defendant’s traffic stop, he admitted possession of meth in his pocket, and that justified a patdown. That led to a search of the car under the automobile exception. Defendant’s consent was irrelevant. State v. Conley, 2019-Ohio-4172, 2019 Ohio App. LEXIS 4246 (4th Dist. Sept. 26, 2019).*