State v. Harris, 2017 Ohio 770

On Nov. 16, 2015 Officer John Meyer went to 109/111 Wood Street to serve an arrest warrant for Christopher Elliott at an address he had listed as his residence.
The front door was open; from the porch Meyer observed several people around a coffee table with items he recognized as heroin and drug paraphernalia in plain view.
After Meyer announced his presence, appellant Flemmon Harris grabbed a small bag and threw it under the table; Meyer entered to seize the items and process the scene.
Harris was indicted for possession of heroin and moved to suppress evidence, arguing the officer lacked probable cause and unlawfully entered the residence.
The trial court denied the suppression motion, found Officer Meyer credible and lawfully present, and the incriminating nature of the items immediately apparent; a jury later convicted Harris and he appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer's warrantless observation/seizure violated the Fourth Amendment	Officer lawfully approached to serve a warrant at listed address; he was on the porch and the contraband/paraphernalia were in plain view, giving probable cause to seize	Harris argued officer lacked probable cause and unlawfully entered, so evidence should be suppressed	Court affirmed: officer was lawfully present, had right of access, and incriminating nature was immediately apparent; suppression denied

State v. Leak, 47 N.E.3d 821 (Ohio 2016) (appellate review of mixed questions of law and fact on suppression)
Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (reasonable suspicion and probable cause reviewed de novo)
Horton v. California, 496 U.S. 128 (U.S. 1990) (plain view doctrine requirements)
State v. Burnside, 797 N.E.2d 71 (Ohio 2003) (trial court as factfinder in suppression hearings)
State v. Mills, 582 N.E.2d 972 (Ohio 1991) (credibility and factual findings for trial court)