OH8: Citizen informant’s 911 call was RS under Navarette

The citizen informant’s 911 call that defendant was drunk, belligerent, and driving gave reasonable suspicion to stop defendant under Naverette. City of Parma v. Coyne, 2024-Ohio-3192, 2024 Ohio App. LEXIS 3019 (8th Dist. Aug. 22, 2024).

“And here, even expunging the information derived from Defendant’s suppressed interview, the warrant affidavit establishes the requisite probable cause.” The trial court erred in suppressing. State v. Broussard, 2024 La. App. LEXIS 1328 (La. App. 3 Cir Aug. 21, 2024).*

“Ofc. Kraft was acting diligently in the course of a missing person investigation, and the facts and circumstances he knew about Josephson’s disappearance at the time he spotted the Impala two blocks from the location where Josephson was last seen surpassed the threshold of a ‘mere hunch or unparticularized suspicion.’ Further, after Ofc. Kraft’s blue lights were activated, Appellant turned the wrong way down a one-way road. This fact coupled with Appellant’s lack of identification, the apparent odor of marijuana emanating from the car, and Appellant’s flight on foot permitted further detention by law enforcement pursuant to Robinson.” State v. Rowland, 2024 S.C. App. LEXIS 70 (Aug. 21, 2024).*

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