State v. Hambleton, 2017 Ohio 7561

Police on a marijuana eradication mission used a helicopter to spot marijuana in a wooded area near a green house off Stagecoach Road.
Ground officers drove into the green house driveway (a landmark) and proceeded on foot across an open field toward the woods after direction from the helicopter.
Officers encountered a man (later identified as Hambleton) in the woods tending marijuana; he was seen throwing plants into a large fire and had a gas can nearby.
Officers restrained Hambleton; he volunteered statements that the plants were his and part of his medical supply. No search warrant was obtained before entering the wooded area.
Hambleton moved to suppress the evidence and argued the entry was an unlawful warrantless intrusion onto his land; the trial court denied suppression, he pled no contest, was sentenced, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers needed a warrant to enter the wooded area and seize marijuana	State: open-fields doctrine applied; aerial observation put plants in plain view and woods were not curtilage	Hambleton: warrant required for physical intrusion onto his land; wooded area was protected curtilage	Court: Woods were open field, not curtilage; warrantless entry and seizure lawful under open-fields doctrine

Oliver v. United States, 466 U.S. 170 (1984) (establishes open-fields doctrine: no Fourth Amendment protection for open fields)
Coolidge v. New Hampshire, 403 U.S. 443 (1971) (plain-view and probable-cause principles regarding warrantless seizures)
Hester v. United States, 265 U.S. 57 (1924) (original formulation of the open-fields doctrine)