OH12: Failure to include CI’s info time frame for SW mooted by confirming trash pull

The CI’s information for the search warrant was not given a time frame, but there was a confirming trash pull within 72 hours of the search warrant, and that mooted the time problem. Also, there is no higher constitutional right in trash in Ohio. An “all persons” warrant was valid. State v. Quinn, 2012 Ohio 3123, 2012 Ohio App. LEXIS 2751 (12th Dist. July 9, 2012).*

Validity of consent to search a backpack in a vehicle was moot where there was probable cause for search of the whole vehicle. State v. Young, 2012 Ohio 3131, 2012 Ohio App. LEXIS 2752 (12th Dist. July 9, 2012).*

Where the IRS was on the premises with a warrant and they found syringes while looking for flashdrives, state officials did not need a separate warrant to come in and take what the IRS was not taking. State v. Lorenzo, 2012 Ohio 3145, 2012 Ohio App. LEXIS 2774 (9th Dist. July 5, 2012).*