State v. Griffin, 2013 Ohio 3036

Officers separately responded to an anonymous tip that people at 4935 Queens Ave. were "making bombs" in a garage and giving them to neighborhood children.
From the street and while walking the driveway (the only access), officers observed a detached garage with its overhead door partially open and a person moving among workstations and mixing bowls.
Officers saw what they identified as gunpowder on tables and scattered on the garage floor; they approached the garage and entered without a warrant or consent.
Inside, officers saw more powders and mixing materials; they handcuffed Griffin after he refused orders and discovered a crack pipe during a search incident to detention.
Officers then observed fireworks in the house through a window, obtained consent from Griffin’s father to search, and called the bomb squad; Griffin was indicted for manufacturing fireworks without a license.
Trial court denied Griffin’s motion to suppress; he pled no contest and appealed, arguing the warrantless entry and searches were unlawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Lawful approach onto property/curtilage	Officers were lawfully on the driveway (open, only access) and could approach garage	Griffin: driveway fence/gate meant curtilage protection	Court: driveway was implicitly open; approach lawful
Probable cause to enter garage	Observations of mixing bowls, gunpowder, and movement gave probable cause of explosive manufacture	Griffin: officers lacked probable cause before entry; he was unaware of officers’ approach	Court: probable cause is arguable, but not necessary to resolve due to exigent circumstances analysis
Exigent / community-caretaking exception	Officers reasonably believed immediate danger existed from apparent bomb-making, justifying warrantless entry to protect public/officers	Griffin: no exigency — he was unaware and bomb squad not called until after entry	Court: anonymous tip corroborated by observations (powder, workstations, actions) created reasonable grounds for emergency aid entry
Suppression of evidence/statements	State: evidence and statements admissible because entry and detention justified	Griffin: items and statements are fruits of unlawful search/seizure and should be suppressed	Court: denied suppression; entry and seizure were reasonable under emergency-aid exception

Payton v. New York, 445 U.S. 573 (warrantless entry of home presumptively unreasonable)
Terry v. Ohio, 392 U.S. 1 (Fourth Amendment seizure/search principles)
Brigham City v. Stuart, 547 U.S. 398 (reasonableness and emergency-aid exigency)
Kentucky v. King, 563 U.S. 452 (limits on warrant requirement and exigent-circumstance analysis)
Michigan v. Fisher, 558 U.S. 45 (police may enter without warrant to render aid when reasonable belief of immediate need exists)
United States v. Dunn, 480 U.S. 294 (curtilage analysis; outbuildings may be within curtilage)
United States v. Oliver, 466 U.S. 170 (Fourth Amendment protection and open fields/curtilage distinction)
State v. Buzzard, 112 Ohio St.3d 451 (plain-view observation from lawful vantage point)
State v. Dunn, 131 Ohio St.3d 325 (Ohio discussion of community-caretaking/emergency-aid exception)
State v. Sharpe, 174 Ohio App.3d 498 (public-safety exigency may justify warrantless entry to retrieve dangerous weapon or ordnance)