State v. Robinson, 2017 Ohio 289

On Oct. 27, 2015 police from Cleveland’s gang-impact unit approached a house on Hampden Ave. after seeing a group of males in the street and a man on the front porch (later identified as Rico Robinson).
Officers observed Robinson make a quick, furtive movement upon seeing police and place a "dark object" on a porch table, then refuse to talk and go inside, locking a door.
Officers entered the yard, approached the porch, observed a loaded Glock 17 on the table in plain view, and later located Robinson inside the home.
Robinson was indicted for having a weapon while under disability (R.C. 2923.13(A)(3)) and carrying a concealed weapon; he moved to suppress evidence obtained when police entered the yard/porch.
The trial court denied the suppression motion; a jury convicted Robinson of having a weapon while under disability (the carrying-concealed charge was dismissed at close of the State’s case). He received community control with a possible prison term on violation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of officers approaching/entering yard and viewing gun (Fourth Amendment)	Police had reasonable, articulable suspicion based on furtive movement in a high-crime area to investigate and approach the porch	Entry onto yard/porch exceeded implied license to approach a home; Jardines bars warrantless intrusions onto curtilage to search for evidence	Court upheld approach: totality of circumstances gave reasonable suspicion; approaching the porch was within the implied license to approach a home and did not require a warrant
Weight/sufficiency of evidence for having a weapon while under disability	Officer testimony that they saw Robinson place a gun on the porch and later recovered it supports conviction	Lack of fingerprint/DNA testing and darkness undercuts officers’ credibility; defense witness said Robinson had no gun earlier	Court held the officers’ testimony was credible; absence of forensic testing did not render conviction against manifest weight of evidence

Mapp v. Ohio, 367 U.S. 643 (1961) (evidence obtained in violation of Fourth Amendment is excluded)
Terry v. Ohio, 392 U.S. 1 (1968) (investigatory stops require specific, articulable facts supporting reasonable suspicion)
Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (warrantless searches are per se unreasonable unless an established exception applies)
United States v. Arvizu, 534 U.S. 266 (2002) (totality of circumstances and officer training inform reasonable suspicion analysis)
Florida v. Jardines, 569 U.S. 1 (2013) (bringing a drug-detection dog onto the front porch to investigate is a Fourth Amendment search)
State v. Bobo, 37 Ohio St.3d 177 (1988) (totality of circumstances justified investigative stop where furtive movements and officer experience suggested danger)
State v. Freeman, 64 Ohio St.2d 291 (1980) (investigatory stop propriety judged by totality of circumstances)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for manifest-weight review)