Police came to do a knock-and-talk, and they could smell a marijuana grow from outside. They decided to do a protective sweep for people before they left to get a search warrant because they heard music from inside the home. They testified they did the sweep to reduce the chance of violence. They photographed and took nothing. The entry was not unreasonable and the motion to suppress was properly denied. State v. Yost, 2019 Ohio App. LEXIS 5514 (5th Dist. Dec. 30, 2019).
The CI here was named and an eyewitness to defendant’s alleged crime, and his detail and named status was sufficient reliability for probable cause. United States v. Jones, 2019 U.S. Dist. LEXIS 223699 (E.D. Mo. Nov. 19, 2019), adopted, 2019 U.S. Dist. LEXIS 222281 (E.D. Mo. Dec. 30, 2019).