OH12: Any error in SW return has no effect on search

Any error in the search warrant return does not affect the search itself. Therefore, it can’t form a basis for suppression. Defendant also disclaimed any interest in the property at the time of the search. State v. McClendon, 2022-Ohio-1441, 2022 Ohio App. LEXIS 1333 (12th Dist. May 2, 2022).

Routine strip searches for inmates returning from court are reasonable, even if female deputies can partially observe them. A strip search of all after a metal part disappeared from a computer was reasonable as an emergency situation, despite the claim it was an “exaggerated response.” Dillon v. Clackamas Cnty., 2022 U.S. App. LEXIS 11754 (9th Cir. Apr. 28, 2022).

“[T]the only issue before us is whether the facts and circumstances known to Green at that time established a reasonable suspicion of drug activity. We hold that they did.” State v. Stonecypher, 2022 Ida. LEXIS 45 (Apr. 29, 2022).*

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