OH2 reverses three

Officers did a knock-and-talk at defendant’s girlfriend’s house where defendant was spending the night. The trial court erred in holding the defendant lacked standing as an overnight guest, and the case is remanded for reconsideration of the motion to suppress. State v. Winston, 2012 Ohio 4743, 2012 Ohio App. LEXIS 4156 (2d Dist. October 12, 2012).*

The state planted a GPS device pre-Jones, and the defendant moved to suppress. The state failed to properly raise a Davis good faith exception argument and forfeited it. State v. Henry, 2012 Ohio 4748, 2012 Ohio App. LEXIS 4161 (2d Dist. October 12, 2012).*

Defendant’s continued detention became unreasonable, and his consent was tainted. State v. Rogers, 2012 Ohio 4753, 2012 Ohio App. LEXIS 4163 (2d Dist. October 12, 2012).*