OH1: Collective knowledge doesn’t require transmission of PC between officers

An undercover officer radioed a patrol officer to stop defendant for impeding traffic for blocking the street while talking car to car. When stopped, the patrol officer didn’t even know the reason for the stop nor where the offense occurred. Still, such details don’t need to be provided for “collective knowledge,” a phrase not even used by the court. State v. Mosley, 2021-Ohio-3472, 2021 Ohio App. LEXIS 3447 (1st Dist. Oct. 1, 2021).

“Notwithstanding any potential errors by the state authorities in retaining Haymon’s phone or turning it over to the federal authorities, because the investigators searched the contents of Haymon’s phone pursuant to a facially valid federal search warrant the district court appropriately determined that the cell phone evidence was admissible under the good faith exception to the exclusionary rule announced in United States v. Leon, 468 U.S. 897, 913, 918-20 (1984). Additionally, we find that, in light of the overwhelming evidence supporting Haymon’s guilt, any error in admitting evidence from Haymon’s phone was harmless. See Chambers v. Maroney, 399 U.S. 42, 53 (1970) (applying harmless error analysis to admission of evidence taken in violation of the Fourth Amendment).” United States v. Haymon, 2021 U.S. App. LEXIS 29669 (4th Cir. Oct. 1, 2021).*