State v. Mendell, 945 N.E.2d 1130

Defendant-appellant Mendell was convicted of having weapons under a disability after a no-contest plea and challenged a suppression ruling.
Mendell argued the arrest warrant was invalid for lack of probable cause and for improper timing of issuance.
Police obtained a complaint, warrant, and affidavit; Mendell allowed entry after being told a warrant existed and a protective sweep occurred.
Mendell consented to a search and disclosed weapons under the bed; two guns were found and seized; Mendell was arrested and transported for interview.
At the police department, Mendell was Mirandized and signed a preinterview waiver; the interview recording began at 1:15 p.m.
The trial court overruled the suppression motion; on appeal, the court found error on probable-cause/good-faith issues and remanded for findings; immunity claim was not properly preserved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for the warrant	Mendell	Mendell	Probable-cause issue to be determined on remand
Timing of warrant before arrest	Mendell	Miamisburg officers	Trial court factual-findings on timing upheld; no error found on this point
Good-faith exception applicability	Mendell	State	Remand for findings on good-faith anticipated under Leon
Statutory immunity under R.C. 2923.23(A) preservation	Mendell	State	Immunity issue not properly preserved; cannot assign error

State v. Williams, 86 Ohio App.3d 37 (1993) (probable-cause and suppression standards for appellate review)
State v. Rodriquez, 66 Ohio App.3d 5 (1990) (arrest valid only if warrant issued prior; probable cause required)
Giordenello v. United States, 357 U.S. 480 (1958) (requirements for arrest warrants and probable cause)
State v. George, 45 Ohio St.3d 325 (1989) (probable-cause review of affidavits; deferential magistrate standard)
United States v. Leon, 468 U.S. 897 (1984) (good-faith exception to the exclusionary rule)