The traffic stop was delayed, and the public safety exception was not applicable, where the officer asked a compound question, and the questioning only appeared directed at getting an admission by appellant that he had drugs on him and suggesting a more thorough search was about to come. State v. Withrow, 2022-Ohio-2850, 2022 Ohio App. LEXIS 2686 (7th Dist. Aug. 9, 2022).
The trial court erred by finding that the search warrant was valid because the court had a conclusory, bare-bones affidavit that omitted critical information deputy could have actually possessed, and included incorrect or misleading information due to either carelessness or intentional indifference to the truth. State v. Hilliard, 2022-Ohio-2849, 2022 Ohio App. LEXIS 2692 (7th Dist. Aug. 9, 2022).*
Defendant lost his CSLI argument on the merits. Reformulating the argument as an ineffective assistance of counsel claim here does no good. Hargett v. United States, 2022 U.S. Dist. LEXIS 146575 (E.D.N.C. Aug. 16, 2022).*