State v. Karns, 2011 Ohio 6109

Appellant Karns appeals the trial court's denial of his motion to suppress evidence found in a locked room at his parents' residence during a February 23, 2010 search.
Castle, a probationer, was assigned to probation officer Harmon and claimed to live at 136 North Ewing with Karns and his parents, triggering a potential probation search.
Castle's completion of a non-probationer waiver form was never completed or returned, and Harmon admitted Castle did not report after February 3 or 4, 2010.
Officers observed cameras directed at the back alley from the residence and later entered a locked bedroom where meth-related evidence was found after gaining entry.
Major-crimes and fire department personnel conducted a warrant-backed full search after initial entry; trial court denied suppression, and Karns was convicted of related drug offenses.
Major issue on appeal: whether the warrantless entry and search of Karns' room was supported by reasonable suspicion under probation-search doctrine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there reasonable suspicion to conduct a warrantless probation search?	State argued probation officers may search a probationer's residence on reasonable grounds.	Karns argued there was no sufficient reasonable suspicion to search the room.	No reasonable suspicion; suppression granted.

State v. Cowans, 87 Ohio St.3d 68 (Ohio 1999) (probation searches may occur with reasonable grounds, not probable cause)
Griffin v. Wisconsin, 483 U.S. 868 (U.S. 1987) (probation searches without warrants under reasonable grounds)
United States v. Knights, 534 U.S. 112 (U.S. 2001) (probation searches may be valid under reasonable suspicion with a search condition)
State v. Benton, 82 Ohio St.3d 316 (Ohio 1998) (parolee/random searches constitutional under certain conditions)
State v. Long, 127 Ohio App.3d 328 (Ohio App. 1998) (appellate review of suppression rulings; weight of evidence findings)