State v. Thompson, 2019 Ohio 2269

In Nov. 2015 Lorain police executed a search of 604 E. 35th St., finding cash, cell phones, >100 grams of cocaine, and other indicia of drug trafficking.
Thompson was indicted Dec. 18, 2015 on multiple drug-possession and trafficking counts with major-drug-offender and forfeiture specifications.
Thompson moved to unseal the warrant/affidavit and filed a motion to suppress the evidence, later amended to allege the search occurred before a valid warrant issued.
A suppression hearing was held; Officer Matthew Bonkoski was the sole witness. The trial court denied the motion in a journal entry that contained no factual findings and stated denial was based on evidence, testimony, credibility, and "good cause."
Thompson pleaded no contest to several counts and received an 11-year sentence plus fines, then appealed solely challenging the denial of the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court’s suppression ruling was supported by competent, credible evidence	Thompson: denial not supported; court failed to make requisite factual findings and improperly applied a "good cause" standard	State: record suffices for review because only one witness testified and evidence is clear	Court: Reversed and remanded — trial court failed to make adequate factual findings and erred in applying a "good cause" standard when denying the motion

State v. Burnside, 100 Ohio St.3d 152 (2003) (standard for appellate review of suppression rulings: accept trial court’s factual findings if supported by competent, credible evidence and review legal conclusions de novo)
State v. Mills, 62 Ohio St.3d 357 (1992) (trial court as factfinder at suppression hearings; assesses witness credibility)
State v. McNamara, 124 Ohio App.3d 706 (4th Dist.) (appellate court duty to independently determine whether facts satisfy legal standard after accepting trial court’s factual findings)