State v. Earns, 196 Ohio App. 3d 731

Defendant-appellant Larry Earns appeals from the trial court’s denial of his motion to suppress evidence obtained from a February 23, 2010 search of premises at 136 North Ewing Street in Lancaster where Misty Castle resided on probation.
Castle, under Fairfield County intensive-probation supervision, lived with Earns and his parents; probation terms allowed searches of residence with consent or reasonable grounds.
A Non-Probationer Acknowledgment and Waiver form for consent to searches was prepared but never completed or signed by the Earns.
Officers observed cameras on the back of the house and a locked bedroom door; they entered the room using a coat hanger and found evidence suggesting methamphetamine activity.
The major-crimes unit later obtained a warrant after detectives validated that the room likely contained a methamphetamine lab, but the suppression motion was denied; the court later remanded after appellate reversal.
Appellant ultimately pled no contest to two counts; the appellate court sustained the suppression challenge and reversed the judgment, remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the warrantless search of Earns’s room supported by reasonable grounds?	Probation officers had reasonable suspicion based on Castle’s probation status and observed indicators.	There was no reasonable suspicion that criminal activity was occurring in Earns’s room; evidence was improperly seized.	The trial court erred; suppression reversed.

State v. Cowans, 87 Ohio St.3d 68 (1999) (probation searches may occur with reasonable grounds without a warrant)
Griffin v. Wisconsin, 483 U.S. 868 (1987) (probation searches may be conducted with less than probable cause)
Knights, United States v. Knights, 534 U.S. 112 (2001) (reasonable suspicion suffices for probation searches under certain conditions)
Benton, State v. Benton, 82 Ohio St.3d 316 (1998) (parole searches constitutional under reasonable-grounds standard)