The search warrant here was based on the CI’s relating largely publicly-known information, some of which was in the newspaper online. It wasn’t predictive, but all historical of criminal record, the kind of car, etc. This is close but no probable cause. Still, however, it is enough for the good faith exception to apply, so suppression denied. United States v. Henry, 2021 U.S. Dist. LEXIS 52237 (D. V.I. (Mar. 19, 2021).
Defendant’s search claim was known before he pled guilty, and it’s based on ineffective assistance for defense counsel not raising his not getting a copy of the warrant at the time of the search. This was waived by the plea and isn’t proper now on post-conviction. [The merits of this issue never prevails, either.] State v. Crespo, 2021-Ohio-848, 2021 Ohio App. LEXIS 838 (8th Dist. Mar. 18, 2021).*