OH9: Def opened a safe for the police but never argued he had a REP in the contents so no standing

Defendant opened a safe for the officers. His wife said that it was hers and she had it before they were married. Defendant didn’t even argue he had a reasonable expectation of privacy in the safe. Therefore, he didn’t show standing. State v. Grondin, 2022-Ohio-3366, 2022 Ohio App. LEXIS 3163 (9th Dist. Sep. 26, 2022).

Officers did not violate the Fourth Amendment in executing an arrest warrant in a house. Defendant was arrested outside, and another they knew was inside. The entry was valid. United States v. Grushko, 2022 U.S. App. LEXIS 26754 (11th Cir. Sep. 23, 2022).

There was reasonable suspicion on the totality. Defendant was driving in a high-crime area and made apparent evasive measures when seeing the police, among other things. United States v. Brown, 2022 U.S. Dist. LEXIS 173239 (E.D. Ky. Sep. 26, 2022).*

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