OH10: Flight was here RS

Defendant was seen hanging out around a market known for dealing in stolen property before it opened for the day. When the officer approached the defendant to ask questions, he fled, and that created reasonable suspicion. State v. Thomas, 2011 Ohio 1191, 2011 Ohio App. LEXIS 1026 (10th Dist. March 15, 2011).*

[Note: Yesterday was this post: LA: Flight easily most important factor in totality. While SCOTUS said in Wardlow that unprovoked flight alone is not enough to be reasonable suspicion, as a practical matter, it doesn’t take much more to make it so. There it was nervousness, but nervousness how, and in a “high crime area.” So, the standard is “flight plus,” but “flight plus” what?]

Police officers entered the house with an arrest warrant for the appellant. They were given permission to search by a co-tenant. From a hallway with a flashlight they could see a box of ammunition in defendant’s room. Appellant denied permission to search the room, so a search warrant was obtained. The view from the hallway was a valid plain view. State v. Jackson, 2011 Ohio 1225, 2011 Ohio App. LEXIS 1058 (5th Dist. March 14, 2011).*