Defendant waived any reasonable expectation of privacy in a cigarette butt he through away where the police found his DNA. It was used to solve a cold case of rape and attempted murder from 1993. State v. Bortree, 2021-Ohio-2873, 2021 Ohio App. LEXIS 2828 (3d Dist. Aug. 23, 2021).
It doesn’t require an admission of consumption of alcohol for reasonable suspicion of DUI to exist, as the trial court held. It can come from defendant’s demeanor and looks and smell. State v. Asbury, 2021-Ohio-2877, 2021 Ohio App. LEXIS 2822 (12th Dist. Aug. 23, 2021).
There was probable cause shown for defendant’s CSLI information despite it being based only in part on a CI’s information. The rest was sufficient, too. State v. Giles, 2021-Ohio-2865, 2021 Ohio App. LEXIS 2820 (6th Dist. Aug. 20, 2021).*