LA: Entry through open door of unoccupied house to extinguish candles reasonable; plain view sustained

Defendant was Tasered and arrested outside his own house at night in an area known for burglaries and trespasses. He said the house was his, and the door was ajar. The officers acted reasonably by going to the open door and calling out for anyone inside. They pushed the door open and saw lit candles. It was reasonable to enter to extinguish them because of the risk of fire if left unattended too long. Cocaine was in plain view, and the entry was reasonable under all the circumstances. State v. Washington, 2012 La. LEXIS 3083 (La. November 16, 2012).*

Use of a PBT to determine a minor in possession case was waived where not presented to the trial court. In re J.J.M., 2012 Ohio 5605, 2012 Ohio App. LEXIS 4844 (7th Dist. December 3, 2012).*

The evidence supported the trial court’s finding that defendant consented to a search of her person for drugs during a stop. City of Ashland v. Zehner, 2012 Ohio 5545, 2012 Ohio App. LEXIS 4826 (5th Dist. November 29, 2012).* Same; search of a house. State v. Jackson, 2012 Ohio 5548, 2012 Ohio App. LEXIS 4827 (5th Dist. November 29, 2012).*