OH3: Look behind refrigerator during exigent entry was inadvertent plain view

The warrantless entry into defendant’s house was justified by the exigency of a child allegedly in peril, which was not in dispute. While waiting for paperwork to be completed, one officer could see slightly behind the refrigerator and saw packaged drugs. This was inadvertent and a reasonable plain view. State v. Frisbie, 2023-Ohio-881, 2023 Ohio App. LEXIS 850 (3d Dist. Mar. 20, 2023).*

2254 petitioner pled no facts to show he was impeded from the state motion to suppress process, so Stone v. Powell bars relief. Boyce v. Shoop, 2023 U.S. Dist. LEXIS 43634 (S.D. Ohio Mar. 14, 2023).*

A mere desire to substantiate a CI’s story does not justify production in discovery of the CI’s files. United States v. Henderson, 2023 U.S. Dist. LEXIS 45909 (W.D. Mich. Mar. 13, 2023).*

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