State v. Harrison (Slip Opinion), 2021 Ohio 4465

Feb. 2, 2018: Detective Joseph supervised a controlled buy of cocaine from Kandale Harrison; the CI and recorded calls provided the basis for probable cause.
Feb. 13: Joseph executed an affidavit (Exhibit 1) describing the buy.
Feb. 27: Joseph swore a one-page complaint before the municipal-court clerk; a blank arrest warrant and the affidavit were attached and delivered to Judge Ann Beck.
Judge Beck stamped and initialed the complaint “Hearing Held / Probable Cause Found,” but the attached arrest warrant itself was left unsigned and undated as part of a court practice to preserve investigative confidentiality.
Mar. 5: Officers arrested Harrison on the road (no force used); a vehicle search incident to arrest yielded inculpatory evidence. The warrant was docketed and signed by a deputy clerk on Mar. 6.
Procedural posture: Trial court suppressed evidence, finding the unsigned warrant invalid; the court of appeals reversed on good-faith grounds. The Ohio Supreme Court affirmed (for a different reason) and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an arrest warrant is invalid under Crim.R. 4 and the Fourth Amendment if the warrant form itself is unsigned	State: The judge’s documented finding of probable cause and the warrant’s incorporation of the sworn complaint satisfy Crim.R. 4 and the Fourth Amendment; signature on the warrant form is not required.	Harrison: The unsigned warrant is facially defective and void ab initio; absence of a signature negates issuance and renders the arrest unlawful.	Court: Valid warrant issued where a neutral judicial officer made a documented probable-cause finding and the arrest warrant expressly incorporated the sworn complaint; lack of signature on the warrant form did not invalidate it.
Whether the good-faith exception applies to officers who relied on an unsigned warrant	Court of appeals: Officers acted in objectively reasonable reliance; applied good-faith exception.	Harrison: Reliance on an unsigned warrant cannot qualify for good-faith protection.	Supreme Court: Did not apply good-faith analysis because the warrant was held valid; exclusionary rule/good-faith exception not reached.

State v. Hoffman, 141 Ohio St.3d 428 (Ohio 2014) (Crim.R.4 requires neutral magistrate probable-cause determination before issuing arrest warrant)
State v. Williams, 57 Ohio St.3d 24 (Ohio 1991) (discusses signature as objective manifestation of magistrate’s intent for search warrants)
Groh v. Ramirez, 540 U.S. 551 (U.S. 2004) (warrant may be construed with reference to an accompanying supporting document if it is incorporated)
United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith exception to exclusionary rule for search warrants)
Massachusetts v. Sheppard, 468 U.S. 981 (U.S. 1984) (good-faith reliance on a warrant that is later found defective)
United States v. Watson, 423 U.S. 411 (U.S. 1976) (warrantless public arrest based on probable cause is constitutional)
Virginia v. Moore, 553 U.S. 164 (U.S. 2008) (valid arrest supports search incident to arrest even if state law required a warrant)
Herring v. United States, 555 U.S. 135 (U.S. 2009) (limits on exclusion when police errors are negligent/not the result of systemic error)
Shadwick v. Tampa, 407 U.S. 345 (U.S. 1972) (clerks may issue warrants if neutral and detached)
Coolidge v. New Hampshire, 403 U.S. 443 (U.S. 1971) (probable-cause determination by neutral magistrate is required)
State v. Brown, 115 Ohio St.3d 55 (Ohio 2007) (reaffirms that warrantless arrests in public based on probable cause do not violate the Fourth Amendment)