OH11: Failure to provide an inventory after a search is ministerial and not a fundamental right

“Even presuming no inventory was completed or provided to Thompson, however, this did not result in prejudice or provide any grounds for relief. It has been held that ‘the preparation and return of an inventory is ministerial’ and ‘does not violate any fundamental rights’ of a defendant.” State v. Thompson, 2019-Ohio-4835, 2019 Ohio App. LEXIS 4881 (11th Dist. Nov. 25, 2019).

Defense counsel filed an Anders brief. “Douglas’ claim in his pro se supplemental brief that the drugs seized during his traffic stop should have been suppressed fails because the exclusionary rule does not apply in supervised release revocation proceedings.” United States v. Douglas, 2019 U.S. App. LEXIS 35199 (4th Cir. Nov. 25, 2019).*

Defendant didn’t show that the statements in the search warrant affidavit were recklessly or deliberately false, and, even if they were, “overwhelming” probable cause remained. State v. Marcellino, 2019-Ohio-4837, 2019 Ohio App. LEXIS 4882 (11th Cir. Nov. 25, 2019).*