OH6: Arrest outside officer’s territorial jurisdiction neither a constitutional violation nor suppressable

Violation of state law on the territorial jurisdiction of officers has already been held not to be a constitutional violation since 1980, so defendant’s stop outside the officer’s jurisdiction was not subject to suppression. This is also consistent with Virginia v. Moore. State v. Jones, 2010 Ohio 1600, 187 Ohio App. 3d 478, 932 N.E.2d 904 (6th Dist. 2010), Decided, Motion granted by, 125 Ohio St. 3d 1511, 2010 Ohio 3331, 930 N.E.2d 330 (2010).*

The state’s efforts to have plaintiff’s child get a psychological test is not a Fourth Amendment claim. Gomez v. Noble County Children Servs., 2010 Ohio 1538, 2010 Ohio App. LEXIS 1287 (7th Dist. March 31, 2010).*

Defendant was arrested for trespassing at a housing project in violation of “No Trespassing” signs, and that justified a search incident. This was not a Terry patdown. State v. Thomas, 2010 Ohio 1548, 2010 Ohio App. LEXIS 1289 (7th Dist. March 30, 2010).*