State v. Dean, 2014 Ohio 448

Officers sought and obtained warrants for Glenn Pendergraft and Connie Dean on menacing charges and went to their shared residence.
Dean agreed to retrieve shoes and secure the residence, with an officer accompanying her inside due to safety concerns.
Inside, officers observed drug paraphernalia and what they believed to be a marijuana cigarette in plain view.
Dean led Officer Chancey Scott to a bedroom after being asked if there was more, resulting in discovery of about 20 marijuana plants.
No Miranda warnings were given prior to questioning, and Dean was subsequently charged with illegal cultivation of marijuana and possession of drug paraphernalia; the trial court denied suppression of physical evidence but sustained suppression of unwarned statements.
Dean argued the bedroom search and the statements were unlawfully obtained and should be suppressed; the court ultimately affirmed denial of suppression of the bedroom evidence and convicted Dean.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dean validly consented to the search.	Dean's consent was involuntary due to lack of Miranda warnings.	Dean did not freely and voluntarily consent; Miranda failures tainted the consent.	Consent was voluntary; no Fourth Amendment violation.
Whether the pre-consent unwarned statements tainted the search under the Fifth Amendment.	Unwarned statements were involuntary and should have suppressed the evidence.	Even without Miranda warnings, voluntary statements do not mandate suppression of physical evidence.	No suppression under the Fifth Amendment; statements were voluntarily given and not the direct cause of the search.

Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. (1973)) (consent search must be voluntary; totality of circumstances considered)
Ohio v. Robinette, 519 U.S. 33 (U.S. (1996)) (courts assess voluntariness of consent from totality of circumstances)
United States v. Watson, 423 U.S. 411 (U.S. (1976)) (custody is a factor, not dispositive, in consent analysis)
State v. Christopher, 2010-Ohio-1816 (Ohio Ct. App. 2010) (consent factors and voluntariness in Ohio context)
State v. Clelland, 83 Ohio App.3d 474 (Ohio Ct. App. 1992) (Miranda warnings not always required for valid consent searches)