The trial court relied on the video of the stop and search, but it was not included by the defense in the record on appeal. This is considered waiver. State v. Hays, 2020-Ohio-2919, 2020 Ohio App. LEXIS 1869 (9th Dist. May 13, 2020).
An ineffective assistance of counsel claim for failure to file a motion to recuse the judge for alleged prejudice in summarily denying a motion to suppress requires an allegation and showing of prejudice that it should or likely would have been granted. Williams v. State, 2020 Fla. App. LEXIS 6514 (Fla. 2d DCA May 13, 2020).