{"id":64275,"date":"2026-06-22T00:00:00","date_gmt":"2026-06-22T05:00:00","guid":{"rendered":"https:\/\/fourthamendment.com\/?p=64275"},"modified":"2026-06-20T13:33:27","modified_gmt":"2026-06-20T18:33:27","slug":"oh1-sw-for-residence-justified-seizure-of-text-messages-about-drug-transactions-received-during-execution-of-warrant","status":"publish","type":"post","link":"https:\/\/fourthamendment.com\/?p=64275","title":{"rendered":"OH1: SW for residence justified seizure of text messages about drug transactions received during execution of warrant"},"content":{"rendered":"\n<p>The warrant for defendant\u2019s residence was based on an affidavit that provided a minimally sufficient nexus between the offenses under investigation and the need to search the home, and the officers acted in good-faith reliance on the warrant. Also, two text messages referencing a drug transaction sent to defendant during the execution of the search warrant was admissible because they directly proved that defendant had the intent and knowledge to sell the drugs he possessed on that day, a necessary element to establish the charged offenses. <a href=\"https:\/\/www.supremecourt.ohio.gov\/rod\/docs\/pdf\/1\/2026\/2026-Ohio-2305.pdf\">State v. Madaris<\/a>, 2026-Ohio-2305, 2026 Ohio App. LEXIS 2280 (1st Dist. June 18, 2026).<\/p>\n\n\n\n<p>\u201cJohnson further contends that the search warrant and arrest warrant were issued without probable cause and that the supporting affidavits omitted material information and were therefore constitutionally defective. \u2026 These claims are barred from federal habeas review.\u201d Stone v. Powell. Johnson v. Dir., Tex. Dep&#8217;t of Crim. Just.-Corr. Insts. Div., 2026 U.S. Dist. LEXIS 136365 (N.D. Tex. May 9, 2026).*<\/p>\n\n\n\n<p><\/p>\n","protected":false},"excerpt":{"rendered":"<p>The warrant for defendant\u2019s residence was based on an affidavit that provided a minimally sufficient nexus between the offenses under investigation and the need to search the home, and the officers acted in good-faith reliance on the warrant. Also, two &hellip; <a class=\"more-link\" href=\"https:\/\/fourthamendment.com\/?p=64275\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[50,5,126],"tags":[],"class_list":["post-64275","post","type-post","status-publish","format-standard","hentry","category-arrest-or-entry-on-arrest","category-cell-phones","category-issue-preclusion"],"_links":{"self":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64275","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=64275"}],"version-history":[{"count":1,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64275\/revisions"}],"predecessor-version":[{"id":64276,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/64275\/revisions\/64276"}],"wp:attachment":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=64275"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=64275"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=64275"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}