2021 Ohio 4205
Ohio Ct. App.2021Background
- On May 23, 2019, Quin was involved in a motor-vehicle crash that killed the other driver; five days later police obtained a search warrant for Quin’s vehicle (including vehicle computer data).
- The warrant affidavit consisted of a single paragraph stating Quin ran a stop sign, struck a Camry, the Camry driver died, and “OVI is a suspected circumstance” with the investigation ongoing.
- Quin was indicted for aggravated vehicular homicide and moved to suppress evidence seized from the vehicle, arguing the warrant lacked probable cause.
- The trial court granted the suppression, finding the affidavit was a “bare bones” affidavit and that the Leon good-faith exception did not apply because the affidavit was so lacking in indicia of probable cause that reliance was unreasonable.
- The State appealed; the Fifth District Court of Appeals affirmed the suppression, holding the affidavit failed to provide a factual basis to support conclusions (running the stop sign; suspected intoxication) and that officers’ reliance was not objectively reasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for warrant to search vehicle for evidence of vehicular homicide/assault/OVI | Affidavit established reasonable belief evidence of those crimes would be in the vehicle (accident, ran stop sign, OVI suspected) | Affidavit was a bare-bones recitation with no factual basis for the stop-sign or OVI assertions | Affidavit insufficient — no facts supporting conclusions; cannot infer probability that vehicle contained evidence of reckless/negligent or intoxicated driving |
| Applicability of Leon good-faith exception | Even if affidavit lacked probable cause, officers reasonably relied on a magistrate-issued warrant | Warrant affidavit was so lacking in indicia of probable cause that belief in its validity was entirely unreasonable | Good-faith exception does not apply because affidavit was bare bones and reliance was objectively unreasonable |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (Fourth Amendment limits on stops/searches)
- Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (probable cause assessed under totality of the circumstances)
- Beck v. Ohio, 379 U.S. 89 (U.S. 1964) (probable cause requires a fair probability, not prima facie proof)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (establishes good-faith exception to exclusionary rule)
- State v. George, 45 Ohio St.3d 325 (Ohio 1989) (Ohio guidance on reviewing magistrate's probable-cause determination; deference to issuing judge)
- State v. Wilmoth, 22 Ohio St.3d 251 (Ohio 1986) (Ohio adoption of Leon's good-faith framework)
- State v. Andrews, 57 Ohio St.3d 86 (Ohio 1991) (Fourth Amendment protection against unreasonable searches/seizures)