State v. Long, 2012 Ohio 3091

Appellant Guy Alexander Long was indicted on multiple counts, including possession of drugs, weapon under disability, receiving stolen property, and safecracking, arising from a no-knock search of his residence.
A motion to suppress the warrant was filed May 18, 2011, with a hearing held June 17, 2011; the trial court denied the motion.
On September 13, 2011, Long pled no contest to all counts except one receiving-stolen-property count, which was dismissed; he was sentenced to an aggregate seven-year term.
Long appeals claiming ineffective assistance of trial counsel for failing to challenge the affidavit supporting the search warrant.
The issue is analyzed under Bradley and related standards requiring deficient performance and prejudice to be shown, with deference to magistrate probable-cause determinations.
The court holds the affidavit had corroboration and there was no actual prejudice, affirming the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance due to suppression challenge	Long argues counsel failed to attack the affidavit's sufficiency.	Long contends the affidavit lacked corroboration and reliability.	No prejudice; warrant supported by probable cause; no relief awarded.

State v. Bradley, 42 Ohio St.3d 136 (Ohio Supreme Court, 1989) (establishes standard for ineffective-assistance review)
State v. Lytle, 48 Ohio St.2d 391 (Ohio Supreme Court, 1976) (requirement of prejudice and reasonable representation)
Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court, 1984) (two-prong deficient performance and prejudice standard)
State v. George, 45 Ohio St.3d 325 (Ohio Supreme Court, 1989) (probable cause sufficiency framework for warrants)