State v. Hoffman (Slip Opinion), 141 Ohio St. 3d 428

Background

In November 2011 Toledo PD detective filed three misdemeanor complaints (theft, criminal damaging, house-stripping) against Brandon Hoffman; deputy clerk issued arrest warrants based on the printed complaint forms that mainly recited statutory elements.
Officers executed those misdemeanor arrest warrants after linking Hoffman to a homicide scene; during arrest they observed and seized a handgun and phones, and later obtained a search warrant based on that information.
Hoffman was indicted for aggravated murder and aggravated robbery; he moved to suppress evidence derived from the arrest, arguing the arrest warrants were invalid because no neutral magistrate made a probable-cause determination and the complaints contained no supporting factual source.
The trial court found the warrants were issued without a probable-cause determination and that Toledo’s clerk procedures were constitutionally defective, but denied suppression under the good-faith exception because local appellate precedent (State v. Overton) had validated similar warrants.
The Sixth District agreed the warrants were invalid but affirmed denial of suppression under a good-faith/reliance-on-precedent rationale; the Ohio Supreme Court accepted review on whether good-faith reliance is possible when a warrant was issued without any magisterial probable-cause finding.
The Ohio Supreme Court held the warrants were invalid (no probable-cause determination) but affirmed denial of suppression because officers reasonably relied in good faith on binding Sixth District precedent approving the procedure; it admonished Toledo Municipal Court to reform its warrant-issuance process.

Issues

Issue	Plaintiff's Argument (Hoffman)	Defendant's Argument (State/Officers)	Held
Were the misdemeanor arrest warrants valid under the Fourth Amendment/Ohio Const. when issued without a neutral magistrate’s probable-cause finding?	Warrants invalid: complaints only recited statutory elements and showed no basis/source for probable cause.	N/A (state conceded lack of magisterial finding for these warrants at trial level).	Held: Warrants were constitutionally invalid—deputy clerk did not make a probable-cause determination.
Is suppression of evidence automatic when a Fourth Amendment violation occurs?	Suppression necessary to remedy constitutional violation and deter systemic misconduct.	Exclusionary rule applies only when deterrence justifies suppression; not appropriate where officers acted in good-faith reliance on existing precedent.	Held: Suppression is not automatic; courts must weigh deterrence and costs of exclusion.
Does the Leon good‑faith exception bar suppression where officers relied on a warrant later found invalid?	Good-faith exception inapplicable because clerk abandoned judicial role and warrants were so lacking in indicia of probable cause that belief in validity was unreasonable.	Officers reasonably relied in objective good faith on binding Sixth District precedent (Overton) approving similar warrants.	Held: Good-faith exception applies—officers acted in objectively reasonable reliance on binding appellate precedent; suppression denied.
Can reliance on binding appellate precedent justify good-faith reliance even when that precedent sanctions defective warrant procedure?	Binding precedent should not save reliance when the warrant is flagrantly defective and magistrates rubber-stamp police.	Davis and Leon allow good-faith reliance where officers follow binding precedent and lack culpability.	Held: Reliance on binding precedent qualifies as good faith; Davis controls—exclusion not warranted here, but court orders procedural reform.

Key Cases Cited

Coolidge v. New Hampshire, 403 U.S. 443 (U.S. 1971) (probable cause must be determined by a neutral, detached magistrate)
Ventresca v. New York, 380 U.S. 102 (U.S. 1965) (affidavits must recite underlying circumstances to allow magistrate’s detached review)
Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (requiring hearing when affidavit contains deliberate or reckless falsehoods)
Lo‑Ji Sales, Inc. v. New York, 442 U.S. 319 (U.S. 1979) (magistrate cannot abandon judicial role and act as adjunct to police)
Brown v. Illinois, 422 U.S. 590 (U.S. 1975) (warrants lacking indicia of probable cause can render reliance unreasonable)
United States v. Leon, 468 U.S. 897 (U.S. 1984) (established good‑faith exception to exclusionary rule for magistrate‑issued warrants)
Arizona v. Evans, 514 U.S. 1 (U.S. 1995) (limits on exclusionary rule depending on source of error)
Herring v. United States, 555 U.S. 135 (U.S. 2009) (exclusionary rule inapplicable where police errors stem from isolated negligence)
Davis v. United States, 564 U.S. 229 (U.S. 2011) (good‑faith exception applies when officers act in strict compliance with binding precedent)
State v. Hobbs, 133 Ohio St.3d 43 (Ohio 2012) (official acting in dual capacities is not a neutral, detached magistrate)
State v. Wilmoth, 22 Ohio St.3d 251 (Ohio 1986) (Ohio adoption of Leon good‑faith exception)
State v. Robinette, 80 Ohio St.3d 234 (Ohio 1997) (Ohio treats Article I, Section 14 coextensively with Fourth Amendment)