State v. Siegel, 2021 Ohio 4208

Siegel was charged with one count of having weapons while under disability after a firearm was found during a search of his residence executed pursuant to a warrant.
The search warrant affidavit was based primarily on a tip from an identified informant, Christopher Masten, arrested during a controlled buy; Masten said he bought heroin and meth from Siegel and had seen drugs at Siegel’s house in the past.
Affiant Sgt. Eric Augenstein verified Siegel’s address and vehicle registration and cited Siegel’s criminal history, but the affidavit did not attest to the informant’s veracity or reliability or describe independent corroboration of drug activity.
The trial court denied Siegel’s motion to suppress; a jury convicted him and he appealed, raising seven assignments of error.
The appellate court concluded the affidavit failed to establish probable cause because the informant’s reliability/veracity was not shown and corroboration was limited to address/vehicle; the affidavit was so deficient that the good-faith exception did not apply.
Court reversed the suppression ruling, reversed the conviction, and remanded; all other assignments of error were rendered moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the search warrant was supported by probable cause based on informant tip	The State: officers corroborated address/vehicle and had surveillance; that corroboration plus criminal history supported probable cause	Siegel: informant was part of criminal milieu; affidavit fails to show informant’s veracity/reliability or independent corroboration of drug activity	Court: Probable cause lacking — affidavit did not attest to informant’s veracity/reliability and corroboration of address/vehicle alone is insufficient; suppression warranted
Whether the good-faith exception saves the search warrant evidence	The State: if probable cause lacking, officers relied in good faith on magistrate’s warrant	Siegel: affidavit was so lacking that reliance was objectively unreasonable	Court: Good-faith exception does not apply — affidavit was so deficient a well-trained officer should have known the search was illegal

United States v. Leon, 468 U.S. 897 (good-faith exception to exclusionary rule)
Illinois v. Gates, 462 U.S. 213 (totality-of-the-circumstances test for probable cause)
United States v. Ventresca, 380 U.S. 102 (deference to magistrate; preference for warrants)
Mapp v. Ohio, 367 U.S. 643 (exclusionary rule applies to states)
Weeks v. United States, 232 U.S. 383 (foundational exclusionary rule)
Alabama v. White, 496 U.S. 325 (anonymous tips require corroboration)
State v. George, 45 Ohio St.3d 325 (Ohio adoption of Gates standard)
Maumee v. Weisner, 87 Ohio St.3d 295 (caution on informant categories; reliability considerations)
State v. Williams, 173 Ohio App.3d 119 (corroboration of address/vehicle insufficient to prove drug activity)
State v. Dalpiaz, 151 Ohio App.3d 257 (veracity and basis-of-knowledge remain relevant indicia of informant reliability)
State v. Gill, 49 Ohio St.2d 177 (affiant's bare assertion of informant reliability insufficient)