State v. Morales, 2018 Ohio 3687

Police Detective Smittle investigated 643 Belvidere Ave. from Jan–Apr 2016, conducting surveillance and identifying occupants alleged to be trafficking drugs.
Two controlled buys (weeks of Mar 13 and Mar 27, 2016) from the residence by a confidential informant were described in Smittle’s affidavit; affidavit filed Apr 27, 2016 and warrant signed same day.
Warrant executed Apr 29, 2016; officers seized a large indoor marijuana grow (29 plants, grow equipment) and later testing showed 477.2 grams of marijuana.
Morales was indicted for possession of marijuana (200–1000 g); he moved to suppress the evidence arguing the affidavit was stale and lacked probable cause, and that the good-faith exception did not apply.
Trial court denied suppression; Morales pleaded no contest, was placed on 3 years community control, and appealed solely on the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether affidavit was stale such that probable cause was lacking for the Apr 27, 2016 warrant	Affidavit showed multi-month surveillance and two recent controlled buys, depicting ongoing drug trafficking that supports probable cause	The most recent corroborating activity was ~1 month before the warrant; drugs are perishable/mobile so the information was stale and insufficient; good‑faith exception shouldn't apply	Court held affidavit, viewed in totality, described ongoing drug activity and provided substantial basis for probable cause; suppression denial affirmed

State v. Burnside, 100 Ohio St.3d 152 (Ohio 2003) (standard of appellate review for suppression rulings)
State v. George, 45 Ohio St.3d 325 (Ohio 1989) (reviewing courts must give great deference to magistrate’s probable-cause determination)
United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith exception to the exclusionary rule)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-the-circumstances test for probable cause)
Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (exclusionary rule applies to states)