State v. Maniaci
2017 Ohio 8270
| Ohio Ct. App. | 2017Background
- On August 11, 2016 MARMET detectives arranged a controlled buy targeting William Maniaci at 860 Kibbey Dr., Apt. C; detectives had a prior June 16 controlled purchase showing Maniaci sold cocaine and boasted of large quantities.
- Detectives obtained an anticipatory search warrant for Apt. C authorizing execution only after three "triggering events": (1) a recorded controlled phone call to Maniaci, (2) Maniaci leaving the apartment, and (3) discovery of cocaine on his person.
- Surveillance on August 11 observed Maniaci leave the apartment twice; after a monitored call and subsequent interaction in a parking area, officers arrested him and found cocaine on his person; detectives then executed the anticipatory warrant and recovered large quantities of cocaine and heroin.
- Maniaci was indicted on first‑degree possession counts with major drug offender specifications and additional trafficking and forfeiture counts; he moved to suppress evidence seized under the anticipatory warrant.
- The trial court denied suppression; Maniaci pled no contest to the possession counts with specifications and was sentenced to concurrent mandatory 11‑year terms. He appealed the denial of the suppression motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of anticipatory warrant—probable cause that triggering events would occur | Warrant affidavit showed ongoing CI relationship and prior controlled buy, supporting probable cause that CI could arrange another buy | Maniaci argued the triggering events were too speculative at time of issuance to meet probable cause | Court held affidavit provided sufficient probable cause that triggering events would occur and were not speculative |
| Nexus between residence and criminal activity | State argued Maniaci identified Apt. C as his residence on recorded calls, CI interactions occurred there, and girlfriend’s registration tied to address | Maniaci claimed he was only an overnight guest and not sufficiently connected to Apt. C | Court held sufficient nexus existed between Maniaci’s trafficking and Apt. C to support search warrant |
| Clarification of the third triggering condition (cocaine on person) | State read condition to allow execution after officers discovered cocaine on Maniaci at arrest (not strictly requiring presence on leaving) | Maniaci read warrant as requiring cocaine on his person when he left the apartment | Court rejected Maniaci’s restrictive reading and found the warrant language reasonably read to permit execution after officers found cocaine at arrest |
| Good‑faith / Leon reliance alternative | State argued even if affidavit had defects, officers reasonably relied on magistrate’s warrant | Maniaci argued defects required exclusion regardless of reliance | Court held affidavit was not so lacking as to render officer reliance unreasonable; suppression denial affirmed |
Key Cases Cited
- Burnside v. State, 100 Ohio St.3d 152 (Ohio 2003) (standard of review for suppression hearing)
- George v. State, 45 Ohio St.3d 325 (Ohio 1989) (probable cause assessed by totality of circumstances)
- Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (fair‑probability/totality‑of‑circumstances test for probable cause)
- United States v. Grubbs, 547 U.S. 90 (U.S. 2006) (validity of anticipatory warrants)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (good‑faith exception to exclusionary rule)
- United States v. Miggins, 302 F.3d 384 (6th Cir. 2002) (triggering event must be explicit, clear, narrowly drawn)
- United States v. Laughton, 409 F.3d 744 (6th Cir. 2005) (distinguishing a "bare bones" affidavit)