CO: These controlled buys were with PC; they could have been “more pristine” but they were adequate

The trial court erred in suppressing the search warrant here because it speculated on things not in the record. The warrant was based on two controlled buys that recounted the CI’s information, the police investigation to corroborate what they could, and how the controlled buys went down. The trial court focused on the failure of the warrant to mention searching the CI’s car as a part of it. “In its suppression order, the trial court concluded that two interrelated problems invalidated the search warrant: (1) assuming the CI drove a car to the buys, the affidavit didn’t state the car had been searched for drugs and money, which cast doubt on the integrity of the controlled buys; and (2) without more pristine controlled buys, the court deemed the CI unreliable.” That’s not the standard of review; it’s whether there is a substantial basis for crediting the CI and the corroboration. People v. McKay, 2021 CO 72, 2021 Colo. LEXIS 972 (Oct. 25, 2021).

Entry into defendant’s motel room to make an arrest validly led to a plain view of stolen property which they photographed. Thus, defense counsel wasn’t ineffective for not making a motion to suppress. State v. Hahn, 2021-Ohio-3789, 2021 Ohio App. LEXIS 3693 (3d Dist. Oct. 25, 2021).