State v. Newman, 2017 Ohio 4047

Law enforcement made multiple controlled buys in early 2015 and obtained a search warrant for a Fairground Road residence (signed April 16, 2015). The warrant form was headed “Cambridge Municipal Court” though signed by the Guernsey County probate/juvenile judge.
Newman was indicted on multiple charges including trafficking and possession of cocaine and related offenses; some drug-possession counts later dismissed.
Newman moved to suppress evidence, arguing the probate/juvenile judge lacked authority to issue the warrant (and the municipal-court caption was fatal); the trial court denied the motion.
A jury convicted Newman on most counts; he was sentenced to 16 years. Newman appealed raising two issues: (1) use of gross weight (including fillers) for enhanced-degree cocaine offenses; (2) invalidity of the search warrant due to issuing judge’s authority and incorrect caption.
The court affirmed: it applied Ohio Supreme Court precedent holding total weight (including fillers) governs cocaine thresholds, and it upheld admission of the search-warrant evidence (finding probate/juvenile judge authority not barred under the circumstances and no prejudice from the caption error; alternatively, Leon good-faith protection was available).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory thresholds for enhanced-degree cocaine offenses are based on gross weight (including fillers) or pure cocaine weight	State: total/gross weight (including fillers) determines offense level	Newman: weight must exclude fillers; only pure cocaine counts toward threshold	Held: gross weight including fillers controls (following Ohio Supreme Court reconsideration)
Whether the search warrant was invalid because it was issued by a probate/juvenile judge and captioned as Cambridge Municipal Court, requiring suppression of evidence	State: warrant valid; caption was clerical error and no prejudice; probate/juvenile judge authority to issue warrant supported and good-faith Leon protection applies	Newman: probate judge lacked authority to issue criminal search warrant and wrong caption invalidates warrant	Held: warrant evidence admissible — probate/juvenile judge’s issuance not precluded here; caption error was clerical and not prejudicial; Leon good-faith alternative applies

United States v. Leon, 468 U.S. 897 (U.S. 1984) (establishes good-faith exception to exclusionary rule)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (probable cause assessed by totality of circumstances)
Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (reasonable-suspicion/probable-cause review is de novo on appeal)
State v. Brown, 142 Ohio St.3d 92 (Ohio 2015) (addressed probate judge authority to issue search warrants)
State v. George, 45 Ohio St.3d 325 (Ohio 1989) (trial judge/magistrate must make common-sense probable-cause determination when issuing warrants)