State v. Muhlenkamp, 2017 Ohio 8352

Muhlenkamp was on community-control (probation) with a signed condition consenting to warrantless searches of person, vehicle, and residence by a probation officer.
On July 5, 2016 he failed an eye-scan drug test, refused a urine test (treated as a failed test), and probation officers received tips he was using and possibly manufacturing methamphetamine.
Probation officer Dane Gross recruited the Grand Lake Task Force to search for a possible meth lab (outbuildings) because of safety concerns about dangerous chemicals.
After the Task Force’s search of outbuildings found no lab, Gross saw Muhlenkamp on the back patio, began arrest procedures for a probation violation (Muhlenkamp had admitted he would test “dirty”), and escorted him inside to retrieve prosthetic legs.
Inside, Gross learned of a digital scale in the bedroom; after arresting and removing Muhlenkamp, Sgt. Crum (Task Force) searched a dresser at Gross’s direction and found baggies containing methamphetamine.
The trial court granted Muhlenkamp’s motion to suppress; the State appealed. The appellate court reversed, holding the warrantless search was authorized by the community-control condition and the Task Force assistance was not a pretext.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a warrantless search of a probationer’s residence conducted by a probation officer with law‑enforcement assistance is lawful	State: Community‑control condition authorized searches; police assistance to a probation officer is permissible and does not invalidate the search	Muhlenkamp: Search exceeded probation scope and was a pretextual law‑enforcement search, so Fourth Amendment protection was violated	Appellate court: Search was lawful — Gross had authority under community control; Task Force assistance was reasonable and not a pretext; suppression was erroneous

Griffin v. Wisconsin, 483 U.S. 868 (recognizes special needs of probation system and upholds warrantless searches under valid state regulation)
State v. Burnside, 100 Ohio St.3d 152 (standard of review for suppression motions: factual findings deferential, legal conclusions de novo)
State v. Cowans, 87 Ohio St.3d 68 (police‑probation collaboration does not automatically render a probation search unlawful)
State v. Benton, 82 Ohio St.3d 316 (warrantless random searches of parolees pursuant to condition are constitutional)
State v. McCain, 154 Ohio App.3d 380 (applies parole/probation search rationale to community‑control sanctions)