State v. Ruffin, 2012 Ohio 1330

Defendant-appellant Damar Ruffin challenges denial of his motion to suppress evidence from a search warrant.
Ruffin pled no contest to possession of cocaine (merged into trafficking) and to related offenses; he received four years’ imprisonment and forfeiture of $1,660.
The suppression ruling was upheld by the Ninth District of Ohio Court of Appeals, which analyzed the warranthood and the affidavit’s veracity.
The affidavit referenced a controlled buy from 1082 South Hawkins Avenue and involvement of a confidential informant as basis for probable cause.
Ruffin raised three assignments of error challenging the probable-cause determination and the good-faith exception, with one assignment deemed moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the warrant supported by probable cause given alleged false statements?	Ruffin contends the affidavit contained false/misleading facts supporting probable cause.	Ruffin argues false statements vitiate probable cause absent reconsideration of the affidavit's entire content.	No reversible error; no false statements shown; warrant sustained by probable cause.
Was the information used to obtain the warrant stale, invalidating probable cause?	Ruffin claims the warrant relied on stale information about an August 23, 2010 buy.	Ruffin contends information close in time to the warrant was too stale to justify seizure.	Good-faith exception applies; information, though partially stale, did not undermine probable cause.
Did the court need to suppress the evidence as fruit of the poisonous tree given stale information?	Ruffin argues suppression is warranted due to tainted seizure.	Ruffin contends suppression is required if the warrant lacked probable cause.	moot; analyzed as non-merits due to other resolved errors.

State v. George, 45 Ohio St.3d 325 (1989) (great deference to magistrate on probable cause; warrant sustained if substantial basis)
State v. Willan, 2011-Ohio-6603 (9th Dist. No. 24894) (attack on affidavit veracity requires false statements; remaining content may still show probable cause)
State v. Waddy, 63 Ohio St.3d 424 (1992) (reckless disregard defined; omissions may mislead magistrate)
State v. German, 2005-Ohio-527 (1st Dist.) (good-faith exception applies when magistrate’s reliance on warrant is objectively reasonable)
United States v. Harris, 6 F. App’x 304 (6th Cir.2001) (consideration of freshness of information and refreshing by recent events)
Sgro v. United States, 287 U.S. 206 (1932) (stale information analysis foundational to probable-cause review)
State v. George, 45 Ohio St.3d 325 (1989) (see above (duplication kept for completeness))