State v. Griesbaum, 2017 Ohio 8363

Defendant Joseph D. Griesbaum was indicted on drug-related felonies after an administrative inspection of his home revealed methamphetamine precursors inside.
City officials obtained an administrative search warrant (March 4, 2016) to inspect the residence and accessory structures for fire-code, zoning, and public-nuisance violations based on persistent exterior hoarding and combustible debris.
The City had previously cited Griesbaum (December 2015) for exterior conditions and had given him until April 2016 to remedy them; officials observed the exterior problems persisted into March 2016.
During execution of the administrative warrant, police observed evidence of hoarding and discovered chemicals for meth manufacture in a garage partition; a criminal search warrant was then sought but the defendant consented to continued search.
Griesbaum moved to suppress, arguing the administrative interior inspection was unreasonable because the City could and should have sought a warrant earlier (when the exterior citation was issued). The trial court denied suppression; Griesbaum pleaded no contest to one count.
The appellate court affirmed denial of the suppression motion, holding the March 2016 administrative warrant was supported by probable cause and objectively reasonable despite the earlier exterior citation and any delay in seeking the warrant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether administrative search warrant for interior was reasonable	Warrant was valid; exterior conditions gave probable cause to inspect interior for fire/safety hazards	Delay between exterior citation and warrant made the March 2016 interior inspection unreasonable and arbitrary	The warrant was reasonable and supported by probable cause; delay or motive did not make the search unconstitutional

Camara v. Municipal Court, 387 U.S. 523 (administrative inspections require warrant to be reasonable under Fourth Amendment)
Brigham City v. Stuart, 547 U.S. 398 (objective circumstances control Fourth Amendment reasonableness irrespective of officer’s state of mind)
Chandler v. Miller, 520 U.S. 305 (searches ordinarily require individualized suspicion)
State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression motions)
State v. Mayl, 106 Ohio St.3d 207 (deference to trial court factual findings in suppression hearings)
State v. Leak, 145 Ohio St.3d 165 (appellate courts independently review legal application after accepting factual findings)