The state didn’t rely on a “reasonable mistake of fact” justification for the stop in the trial court, so it can’t for appeal. State v. Turner, 2021-Ohio-541, 2021 Ohio App. LEXIS 564 (12th Dist. Mar. 1, 2021).
Defendant had some limited connection to the premises searched and stayed there on occasion, but he wasn’t around when the search occurred. He didn’t even know who owned it, and he had no key. He doesn’t object to any facts in the R&R, just the application of the law. United States v. Reverand, 2021 U.S. Dist. LEXIS 37077 (W.D. Tenn. Mar. 1, 2021).*