OH2: Drugs represented to be heroin in a controlled buy don’t have to be field tested to show PC

Failure to field test the purported drugs bought during a controlled buy doesn’t undermine the probable cause alleged in the search warrant. “Here, the fact that Glynn represented to the CS that the substance being purchased was heroin warranted suspicion as to the illicit nature of the substance that rose to the level of probable cause. Given the totality of the circumstances in this case, which included the information provided by the CS and Det. Neiford’s observations, we find that there was a substantial basis for the issuing judge to conclude that the substance purchased at Glynn’s residence was an illegal drug.” State v. Glynn, 2020-Ohio-4763, 2020 Ohio App. LEXIS 3642 (2d Dist. Oct. 2, 2020).