State v. Johnson, 190 Ohio App. 3d 750

Defendant Johnson was convicted in Butler County Court of Common Pleas of trafficking in cocaine and related offenses; convictions were upheld on appeal.
Informants provided multiple tips that Johnson was trafficking cocaine, including recent dispersal of kilos and plan to acquire more.
Detectives attached a magnetized GPS device to Johnson’s van after a trash pull, without a warrant, and tracked its movements.
GPS data placed the van near a Chicago shopping center; corroborating officers observed Johnson and another man in the van, then followed to a residence.
Law enforcement stopped Johnson for a marked-lane violation, conducted a canine sniff, obtained consent to search, and seized seven kilos of cocaine in a separate vehicle (Ford) carrying Otis Kelly; Johnson’s van yielded no drugs at first.
After Miranda warnings, Johnson admitted involvement and led to warrants for searches of his home and storage unit, yielding additional contraband.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether GPS device placement on the van required a warrant.	Johnson	Johnson	GPS not a search; no warrant required.
Whether the traffic stop and subsequent detention/search were lawful.	Johnson	Johnson	Stop lawful; detention and canine search valid.

Knotts, 460 U.S. 276 (U.S. 1983) (tracking via beeper not a search; mere surveillance of movements on public roads permissible)
Katz, 389 U.S. 347 (U.S. 1967) (establishes two-part privacy expectation test for searches)
Kyllo, 533 U.S. 27 (U.S. 2001) (privacy expectations when using device not in general public use; requires warrant in home surveillance)
Robinette, 80 Ohio St.3d 234 (Ohio 1997) (Ohio Constitution not broader than Fourth Amendment for searches)
Mays, 119 Ohio St.3d 406 (Ohio 2008) (traffic stop valid with observed marked-lane violation; probationary detention permissible)
Rascon-Ortiz, 994 F.2d 749 (10th Cir. 1993) (GPS tracking parallel to traditional surveillance; no search)