State v. Bass, 2012 Ohio 3275

P.K. reported a hand outside her window through a torn screen, wearing a hoodie, prompting police involvement.
Officers Gault and Knoth investigated Bass as a suspect in prior window-peeping incidents and found a bicycle and backpack in Bass’s backyard.
Gault observed Bass under a street light about two hours after the incident and arrested him without questioning, based on recognition and matching description.
Bass was Mirandized, admitted being outside P.K.’s window, and was charged with attempted burglary and voyeurism.
The trial court denied suppression; Bass was convicted on both counts and sentenced to concurrent terms, with Tier I designation; Bass appeals on suppression and sufficiency grounds.
The court reviews the suppression ruling de novo for legal questions while giving deference to factual findings, ultimately upholding probable cause for arrest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause to arrest Bass existed?	Bass lacked probable cause; description was general and not enough.	Gault relied on a vague description and prior offenses without solid linkage to the crime.	Probable cause existed; facts created fair probability Bass committed the crime.
Sufficiency of evidence for voyeurism	Evidence insufficient to show trespass for sexual arousal.	State failed to prove purpose to sexually arouse or gratify.	Evidence legally sufficient; admissions and statements establish trespass for voyeuristic purpose.

State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (standard for circumstantial-evidence sufficiency)
State v. Kulig, 37 Ohio St.2d 157 (Ohio 1974) (overruled; circumstantial-evidence rule softened)