N.D.Ohio: The residence had two front doors but could not be definitively determined to be two residences before search; search still valid when it was two

The residential building searched had two front doors but one address. This suggested that it might be two residences, but police investigating couldn’t find any indication that it was two, not one. In any event, the warrant was based on probable cause, and the only remedy, if any, would be partial suppression. But still: “This case is more like Woodbury, where the discovery on entry that the residence contained more than one dwelling unit did not negate or undermine the warrant’s provided probable cause for the search of the entire property. Further, as in Woodbury, the officers’ decision in the instant case to continue their search despite the internal subdivision of the residence into two units was, as in Garrison, ‘objectively understandable and reasonable.’ Woodbury, 485 F. App’x at 60.” United States v. Osley, 2024 U.S. Dist. LEXIS 37791 (N.D. Ohio Mar. 5, 2024).

“The totality of the circumstances consisted of the following facts when Detective Jaynes stopped Paul: (1) Detective Jaynes observed Paul in the vicinity of the convenience store shortly after the robbery occurred; (2) Paul had a ‘bulge in his right front pant pocket’ that could have been a ‘knife or possibly money that was collected from the robbery’; and (3) the photographs Detective Jaynes received showed that some of Paul’s clothing bore similarities to those worn by the actual robber. Taken together, these circumstances gave rise to reasonable suspicion that Paul committed the robbery.” United States v. Paul, 2024 U.S. App. LEXIS 5087 (6th Cir. Mar. 1, 2024).*

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