OH5: Landlord’s limited entry to basement was valid private search

Defendant’s basement was subjected to a valid private search by his landlord where the landlord could access the basement at will. Stolen air conditioners were hidden there, and the landlord photographed them and told the police who got a search warrant. State v. Hughes, 2013 Ohio 459, 2013 Ohio App. LEXIS 398 (5th Dist. February 8, 2013);* State v. Hughes, 2013 Ohio 458, 2013 Ohio App. LEXIS 397 (5th Dist. February 8, 2013).*

A GPS placed at the border pre-Jones was valid under Davis. United States v. Williams, 507 Fed. Appx. 728 (9th Cir. 2013).*

Defendant was accused with others of running a meth lab out of a shed that the police thought was abandoned. He claimed it was family property, but he failed to show an expectation of privacy in it and he fares no better than the drug operation in Carter. United States v. Skoda, 705 F.3d 834 (8th Cir. 2013).*

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