State v. Jones
143 Ohio St. 3d 266
Ohio2015Background
- Detectives sought a warrant for 1116 Rowley Avenue based on a multifactor affidavit tying Jones to meth activity; informant tips referenced a known meth cook and connections to Chappell.
- Prior arrests linked to the address included Taylor’s manufacture of methamphetamine and Shpilman’s arrest at 1116 Rowley for meth-related activity.
- An undercover informant described Jones as a meth producer/seller; several arrestees identified Chappell as a meth cook associated with Rowley Avenue.
- March 2012 sighting at the courthouse connected Chappell to Jones; a computer check confirmed Jones’s Rowley address and December 2011 burglary/arrest links.
- A trash pull at 1116 Rowley yielded mail to Jones, meth-related containers, and meth residue, prompting a search warrant within 24 hours.
- Executing the warrant revealed an active meth lab and Jones’s linkage to production; Jones was indicted on eight felony counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a trash pull plus corroborating information supports probable cause | Jones argues a single trash pull cannot establish probable cause | State contends corroborating tips/background satisfy probable cause | Yes; totality of circumstances supports probable cause |
| Whether trash pulls must be viewed in isolation under Weimer | Jones relies on isolation of trash contents per Weimer | State contends trash pull is part of totality of circumstances | No; consider trash pull as part of totality of circumstances |
| What standard governs after-the-fact review of the warrant affidavit | Jones argues strict scrutiny not required | State emphasizes Gates/totality framework | Gates totality-of-circumstances applied; deference to magistrate upheld |
| Whether the trash-pull rule is a bright-line or flexible test | Jones urges strict rule against trash pulls | State urges as corroborating factor | Not a bright-line rule; totality of circumstances governs |
| Whether the evidence should have been suppressed | Jones seeks suppression due to lack of probable cause | State asserts probable cause existed | No suppression; warrant valid under totality framework |
Key Cases Cited
- Illinois v. Gates, 462 U.S. 213 (U.S. Supreme Court 1983) (totality-of-the-circumstances prob. cause standard)
- State v. George, 45 Ohio St.3d 325 (Ohio 1989) (defer to magistrate on probable cause; resolve doubtful cases in favor of upholding warrants)
- State v. Smith, 124 Ohio St.3d 163 (Ohio 2009) (equal protection of Ohio Constitution; Fourth Amendment analogue)