State v. Castagnola, 145 Ohio St. 3d 1

Background

Police sought and a municipal judge issued a search warrant for Castagnola’s residence after texts and a recorded conversation implicated him in damaging the prosecutor Maistros’s vehicles. The affidavit sought “records and documents stored on computers” among other electronic media.
The affidavit paraphrased a recorded conversation as saying Castagnola had “found Maistros online in the clerk of courts,” but the recording did not contain the word “online”; it did contain that Castagnola had to “look up” Maistros on court records and checked the mailbox to confirm the address.
Officers seized two computers; a BCI analyst examined a recently used hard drive and found data leading to separate child-pornography evidence and a second warrant; that search produced additional criminal charges.
Castagnola moved to suppress, arguing (1) the affiant presented an undisclosed inference as fact (usurping the magistrate’s role) and (2) the warrant lacked the Fourth Amendment particularity required for searching a computer. The trial court and Ninth District denied suppression; the Ohio Supreme Court accepted review.
The Ohio Supreme Court held the warrant invalid: the affiant negligently presented an undisclosed, significant “online” inference as fact (usurping the magistrate’s role), and the warrant failed to describe with sufficient particularity the items to be searched on the computer. The Court suppressed the evidence and reversed.

Issues

Issue	Plaintiff's Argument (Castagnola)	Defendant's Argument (State)	Held
Whether the affiant improperly presented an undisclosed inference as empirical fact, usurping the magistrate’s role	Affiant inferred (but did not disclose) that the address-search was done online; that undisclosed inference was significant and should have been tested by the magistrate	The affidavit allowed reasonable inferences; magistrate may rely on affiant’s reasonable interpretation under the totality of circumstances	Held: Affiant negligently usurped magistrate’s inference-drawing; the “online” inference was significant and must be excised; without it, no probable cause that evidence would be on a home computer
Whether the warrant satisfied the Fourth Amendment particularity requirement for searching a computer	Warrant was overbroad and authorized a general exploratory search of all “records and documents stored on computers” without limiting what types of files or where relevant data would be found	Warrant was as particular as circumstances permitted and identified the offenses and categories of items connected to those offenses	Held: Warrant failed particularity—did not guide or limit the computer search; allowed seizure of irrelevant, non-specified data and therefore was invalid
Whether the good-faith exception to exclusion applies to salvage the seized evidence	Evidence should be suppressed because the warrant was not reasonably relied upon by officers—warrant was both based on layered inferences and was facially deficient in particularity	Officers reasonably relied on a magistrate-issued warrant; suppression unnecessary under Leon good-faith exception	Held: Good-faith exception does not apply—affidavit lacked indicia of probable cause and warrant was so facially deficient that objectively reasonable reliance was not justified; suppression ordered

Key Cases Cited

Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-the-circumstances standard for probable cause)
United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith exception to exclusionary rule)
Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (standard for requiring an evidentiary hearing when affidavit contains intentional or reckless falsehoods)
Groh v. Ramirez, 540 U.S. 551 (U.S. 2004) (particularity requirement is a warrant prerequisite; warrants must describe with particularity the place and things to be seized)
State v. George, 45 Ohio St.3d 325 (Ohio 1989) (reviewing court must ensure magistrate had substantial basis for probable cause)
State v. McKnight, 107 Ohio St.3d 101 (Ohio 2005) (standard for material falsehoods/omissions in affidavit requiring intentional or reckless conduct)
People v. Caffott, 105 Cal.App.3d 775 (Cal. Ct. App. 1980) (test for when an affiant’s undisclosed inference improperly usurps magistrate’s role)