OH7: Attached affidavit made SW particular

While the search warrant wasn’t particular, it incorporated the affidavit which was. State v. Bugno, 2022-Ohio-2008, 2022 Ohio App. LEXIS 1882 (7th Dist. June 9, 2022).

The emergency aid exception applies: “[T]he presence of blood on the premises, coupled with two separate 911 calls reporting that a violent incident involving several people had just taken place on the Hillards’ property, provided officers with reason to believe others may have needed immediate aid, justifying a brief, warrantless search.” The re-entry to look at surveillance video inside the house produced nothing and is moot. State v. Hillard, 2022 Kan. LEXIS 69 (June 10, 2022).

“Police officers may handcuff a suspect during a Terry stop to protect their personal safety and maintain the status quo.” “The evidence favors the Government’s view that the Overland police officers had reasonable suspicion of criminal activity involving Smith and the rental car to temporarily detain him in order to verify or dispel Sgt. Lydon’s suspicions.” “Officers thereafter developed the probable cause to arrest Smith as the encounter evolved.” United States v. Smith, 2022 U.S. Dist. LEXIS 104983 (E.D.Mo. May 20, 2022),* adopted, 2022 U.S. Dist. LEXIS 104945 (E.D.Mo. June 13, 2022).*

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