State v. Amodio, 2012 Ohio 2682

Amodio resided in the basement of the Vanhauters’ home at 532 Wolf Avenue, Wadsworth.
Medway DEA executed a search warrant there on July 22, 2010 and found two burnt spoons with residue and syringes; residue tested positive for oxycodone.
A grand jury indicted Amodio on one count of knowingly possessing oxycodone.
The trial court denied Amodio’s motion to suppress; Amodio was convicted by a jury and sentenced to three years of community control.
The basement was argued to be a separately-secured area outside the warrant’s scope, but the court held the warrant valid for the entire residence.
The Court of Appeals affirmed both the suppression ruling and the sufficiency/weight determinations, upholding the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant sufficiently described the place searched.	Amodio: basement is separately secured; warrant did not cover it.	Medway: basement part of the residence described in the warrant.	No error; warrant extended to the entire residence, including basement.
Whether the evidence was sufficient and not against the manifest weight to support the possession conviction.	Amodio: insufficient evidence; did not knowingly possess oxycodone.	Medway: sufficient evidence; conduct and substances showed knowledge and possession.	Conviction supported by sufficient evidence and not against the manifest weight.

State v. Mills, 62 Ohio St.3d 357 (1992) (mixed review: trial findings and legal conclusions de novo on suppression)
State v. Fanning, 1 Ohio St.3d 19 (1982) (standard for reviewing suppression findings)
State v. McNamara, 124 Ohio App.3d 706 (1997) (de novo review of legal conclusions after factual findings)
State v. Burnside, 100 Ohio St.3d 152 (2003) (probable cause and particularity requirements under Fourth Amendment)
State v. Conley, 9th Dist. No. 08CA009454, 2009-Ohio-910 (2009) (suppression standard and factual-reasoning framework)
State v. Vu, 9th Dist. No. 11CA0042-M, 2012-Ohio-746 (2012) (probable cause and warrant particularity)
Maryland v. Garrison, 480 U.S. 79 (1987) (purpose of particularity requirement in warrants)
State v. Overholt, 2003-Ohio-3500 (2003) (warrant specificity guidance)
State v. Armstead, 2007-Ohio-1898 (2007) (scope of warrants in complex premises)
United States v. Harris, 903 F.2d 770 (10th Cir.1990) (scope and description sufficiency for warrants)
State v. Scott, 1989 WL 100995 (1989) (single warrant covers multiple occupants in shared premises)