State v. Riedel, 100 N.E.3d 1155

Background

Defendant Justin Riedel was indicted on multiple counts; following trial the jury convicted him of domestic violence (R.C. 2919.25) and illegal cultivation of marijuana (R.C. 2925.04); other counts were acquitted. Sentencing: one year community control.
Police responded to Facebook messages alleging the victim (D.F.) was being held and beaten at Riedel’s home; SWAT secured the residence and Riedel was taken into custody when he and D.F. exited.
While handcuffed in a patrol car, Riedel signed a written consent-to-search form after speaking with Sergeant Ross; detectives then searched and seized firearms, body armor, and ≈1,177 grams of marijuana and cultivation equipment.
Riedel moved to suppress the search results, alleging coerced consent, that he had requested counsel, and that Miranda warnings were not given; the trial court suppressed post-arrest statements but denied suppression of the search evidence, finding consent voluntary.
At trial the state presented photographic and detective testimony about the grow operation and D.F.’s injuries; D.F. testified about abuse and prior cohabitation with Riedel; Riedel testified he did not cultivate the plants and disputed the assault account.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of consent search	State: consent was voluntary; officers explained rights and defendant signed a written waiver.	Riedel: consent was coerced (arrest, show of force, alleged threats) and involuntary.	Consent voluntary under totality; trial court credited officers and bodycam; motion to suppress denied.
Miranda and invocation of counsel	State: consent requests are not custodial interrogation requiring Miranda; absence of warnings doesn't invalidate consent.	Riedel: he had requested counsel and was not Mirandized, so consent and fruits should be suppressed.	Miranda warnings not required to validate a consent-to-search; suppression not required for physical evidence.
Jury instruction on "household member" element	State: instruction adequately allowed conviction given written materials and verdict form.	Riedel: oral instruction incorrectly used "and/or," altering statutory element and reducing state’s burden.	Trial court erred in the oral formulation but no plain error — written instructions and forms contained correct statutory definition; verdict stands.
Sufficiency / manifest weight of evidence (cultivation & domestic violence)	State: photographic, detective, and victim testimony support cultivation and domestic-violence elements (including prior cohabitation within 5 years).	Riedel: lack of proof he knowingly cultivated; victim not credible; injuries could be accidental.	Evidence sufficient and not against manifest weight: jury reasonably credited state’s circumstantial evidence and victim’s testimony; convictions affirmed.

Key Cases Cited

Schneckloth v. Bustamonte, 412 U.S. 218 (voluntariness of consent determined from totality of circumstances)
Bumper v. North Carolina, 391 U.S. 543 (state must show consent was freely and voluntarily given)
Mapp v. Ohio, 367 U.S. 643 (exclusionary rule for unconstitutional searches)
United States v. Watson, 423 U.S. 411 (custody alone does not automatically render consent involuntary)
Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required before custodial interrogation)
Schmerber v. California, 384 U.S. 757 (Fifth Amendment protects compelled testimonial communications)
State v. Burnside, 100 Ohio St.3d 152 (standard of review for suppression rulings)
State v. Jenks, 61 Ohio St.3d 259 (sufficiency standard of review)
State v. Thompkins, 78 Ohio St.3d 380 (manifest weight standard of review)
State v. McGlothan, 138 Ohio St.3d 146 (when parties shared residence, cohabitation element satisfied without additional proof)
State v. Williams, 79 Ohio St.3d 459 (factors for evaluating cohabitation)