On a DV call, the officer approached the front door of defendant’s house to knock, but he paused to listen to voices inside. That listening before knocking was not an unreasonable search. State v. Kunkle, 2023-Ohio-661, 2023 Ohio App. LEXIS 624 (6th Dist. Mar. 3, 2023).
“Here, in his pretrial motion, Adorno claimed that the search of his apartment ‘was based upon materially false information that was contained in the Affidavit of Probable Cause.’ Omnibus Pretrial Motion, at ¶ 5. However, he did not claim that Officer Petrucci made deliberately false statements or made statements with a reckless disregard for the truth. Furthermore, Adorno did not make an offer of proof of such. Therefore, the court erred in granting Adorno’s suppression motion. … We therefore reverse the order granting Adorno’s suppression motion.” Commonwealth v. Adorno, 2023 PA Super 34, 2023 Pa. Super. LEXIS 78 (Mar. 3, 2023).*