OH3: Arrest of drug offender coming home outside his house led to officers hearing “scurrying about” inside, and that justified warrantless entry

One man under investigation for drug crimes was arrested outside a house when officers went there waiting for him to arrive. On the arrest, officers heard others inside “scurrying around” [how?]. This created exigency and justified a warrantless entry into the premises to prevent destruction of evidence. It was reasonable for the officers to conclude that because the person stopped coming home was a drug offender, so were the people he was living with. “Notwithstanding the trial court’s conclusion [of protective sweep], we conclude that, based on the totality of the circumstances of this case, exigent circumstances existed to justify the warrantless entry and limited search of the residence because competent, credible evidence exists in the record reflecting that it was reasonable for law enforcement to believe that the drug evidence was at risk of being destroyed if the officers did not immediately enter to secure the scene. See King, 563 U.S. at 457; Benvenuto, 2018-Ohio-2242, at ¶ 25; Johnson, 457 Fed.Appx. at 515; United States v. Waide, E.D.Ky CR No. 5:18-116-KKC, 2019 U.S. Dist. LEXIS 60014, 2019 WL 1521973, *7 (Apr. 8, 2019).” State v. Reilly, 2020-Ohio-850, 2020 Ohio App. LEXIS 777 (3d Dist. Mar. 9, 2020). [Note: So guilt by association of everyone inside? Police created exigency?]