The good faith exception does not apply to warrantless searches. State v. Peeks, 2021-Ohio-3045 (10th Dist. Sept. 2, 2021).
The trial court erred in finding the affidavit for search warrant to be bare bones and not entitled to the good faith exception. “Under this legal framework, we conclude, after reading the affidavit holistically, examining the totality of the circumstances, and employing a healthy dose of common sense, that it is not a ‘bare bones’- affidavit. The affidavit contains much more than simply ‘suspicions or conclusions.’ The affidavit includes sufficient factual content to establish ‘some connection’ between suspected illegal activity, i.e., drug trafficking, and Clover Glade. In particular, the affidavit includes detailed facts about all three controlled drug buys, including the dates of the first and third transactions and Pollard’s personal involvement in those transactions.” State v. Battles, 2021-Ohio-3005 (10th Dist. Aug. 31, 2021).*