State v. Campbell, 2014 Ohio 5315

BURN received multiple informant tips and cooperating-defendant statements that Billy Campbell traveled to the Boston area, rented cars, and trafficked heroin back to Butler County with his wife and children.
Surveillance confirmed a rental car at Campbell's home and later that the family's cell phone (belonging to Campbell's wife) was pinged in Massachusetts and tracked back toward Ohio.
BURN relayed investigative information to Butler County deputies; Deputy Betz, at BURN's direction, stopped Campbell's rental car as it returned to Butler County.
A drug canine alerted on the vehicle; officers found marijuana in a door compartment and heroin in a suitcase in the trunk.
Campbell was Mirandized at the roadside, transported to the station, again advised of rights, then questioned; some recording equipment malfunctioned.
Campbell moved to suppress the phone-ping evidence, the warrantless vehicle stop/search, and his statements; the trial court denied suppression, he pled no contest, was convicted of trafficking/possession, and sentenced to 11 years.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of GPS/phone-ping warrant and standing to challenge	Warrant supported by probable cause; pinging tracked location relevant to suspected trafficking	Campbell: pinging was an illegal search; lacked probable cause; interstate pinging unlawful	Court: Campbell lacked standing to challenge ping of his wife’s phone; even if he had standing, pinging was supported by probable cause and no law barred interstate tracking
Lawfulness of investigatory stop and resulting vehicle search	Stop justified by collective information from BURN and deputies (reasonable suspicion); canine alert justified search	Campbell: deputy lacked personal knowledge and there was no traffic violation or individualized suspicion to stop the car	Court: Totality of circumstances (numerous reliable informants, surveillance, rental-car pattern, phone pings, Deputy Betz’s involvement) supplied specific, articulable facts for a Terry stop; denial of suppression affirmed
Admissibility of statements (Miranda)	State: officers read Miranda at scene and at station; waiver was knowing and voluntary	Campbell: recording failures and lack of signed waiver show rights were violated; waiver involuntary	Court: Miranda warnings were given twice; no evidence of coercion; absence of signed/recorded waiver does not invalidate a verbal waiver; statements admissible

Rakas v. Illinois, 439 U.S. 128 (personal Fourth Amendment standing cannot be vicariously asserted)
United States v. Salvucci, 448 U.S. 83 (standing and expectation of privacy requirements for Fourth Amendment claims)
United States v. Skinner, 690 F.3d 772 (6th Cir.) (no reasonable expectation of privacy in cell-site data emitted by voluntarily procured phone)
Terry v. Ohio, 392 U.S. 1 (establishing standard for investigatory stops requiring specific and articulable facts)
United States v. Cortez, 449 U.S. 411 (totality-of-circumstances test for reasonable suspicion)
Alabama v. White, 496 U.S. 325 (informant reliability and content relevant to reasonable suspicion analysis)
City of Maumee v. Weisner, 87 Ohio St.3d 295 (Ohio law permitting traffic stops to investigate reasonable suspicion of criminal activity)
State v. George, 45 Ohio St.3d 325 (magistrate’s role and deference in determining probable cause for search warrants)
State v. Coleman, 45 Ohio St.3d 298 (Fourth Amendment rights are personal and not vicariously asserted)