State v. Powell, 2012 Ohio 5104

Powell suspected of growing marijuana in his detached garage based on an early-morning tip (Oct. 3, 2010).
Detective Curnutte conducted a warrantless investigation, entering Powell’s home with multiple officers after a knock-and-talk.
Powell consented to a search of the garage via a written consent form, which was explained to him prior to signing.
During a back-property walk, the detective saw marijuana drying inside the house and obtained consent to search further.
18 marijuana plants, seed tray, razor blades, pH Up, a digital scale, and bags of marijuana were recovered.
Powell moved to suppress, arguing the consent was involuntary; the trial court denied the motion, and Powell pled no contest to predicate offenses while appealing the denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Powell’s consent to search voluntary under the Fourth Amendment?	Powell alleged coercion due to timing, police presence, and lack of advisory rights.	Powell argued consent was not voluntary and was the product of coercion.	Yes; consent was voluntary under the totality of circumstances.

Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. 1973) (consent must be voluntary; coercion undermines validity)
Posey, 40 Ohio St.3d 420 (Ohio 1988) (clear-and-convincing standard for voluntariness of consent)
Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (consent obtained under intimidation is not true consent)
Xenia v. Wallace, 37 Ohio St.3d 216 (Ohio 1988) (established exceptions to warrant requirement including consent)