OH12: Dog alert on car and def’s person didn’t justify strip search

There was reasonable suspicion for and continuing defendant’s stop. A dog sniff was permitted. The dog’s alert, however, didn’t permit a strip search of defendant. It did permit a search of the person. State v. Owensby, 2022-Ohio-1702, 2022 Ohio App. LEXIS 1592 (12th Dist. May 23, 2022).

Even though the officer had probable cause for a search warrant, his threat to “toss” defendant’s father’s place and unreasonably search it was coercion for defendant’s statement. United States v. Jacobs, 2022 U.S. Dist. LEXIS 92701 (E.D.Ohio May 24, 2022).

The warrant affiant doesn’t have to be the one involved in the controlled buy under collective knowledge. United States v. McCallister, 2022 U.S. App. LEXIS 13964 (4th Cir. May 23, 2022).*

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