State v. Young, 2019 Ohio 4639

Kali E. Young was indicted for possession of cocaine (second-degree felony) and heroin (fifth-degree felony).
A known, previously reliable confidential informant identified "Kali," gave a phone number and vehicle description, and arranged a controlled buy using prerecorded funds.
Detectives surveilled Young leaving 1008 Caldwell Place, observed him drive to the buy location, complete a brief hand-to-hand transaction with the informant, and return directly to 1008 Caldwell Place where he used keys to enter.
The affidavit recited the controlled buy, the informant searches (no contraband found), field test of recovered substance as cocaine, and Detective Earl’s narcotics investigation experience; a warrant was issued and executed within 72 hours, yielding heroin, cocaine, and cash.
Young moved to suppress, claiming no nexus/probable cause to search 1008 Caldwell Place; the trial court denied suppression, Young pleaded no contest, was convicted and sentenced, and appealed.
The State later moved to dismiss the appeal under the fugitive-disentitlement doctrine after Young absconded; the court treated that motion as moot after resolving the suppression issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant affidavit established probable cause / nexus between drug activity and 1008 Caldwell Pl	Warrant affidavit (informant + observed controlled buy + surveillance) established probable cause to search residence	Informant did not say he had been inside or seen drugs at the residence; affidavit therefore lacked nexus to support warrant	Court upheld warrant: surveillance of departure, buy, and return plus detective experience gave magistrate a substantial basis to find probable cause
Whether appeal should be dismissed under fugitive-disentitlement doctrine	State: Young’s absconding from house arrest disentitles him to appeal	Young: (not adjudicated on appeal due to resolution of merits)	Moot — court overruled the substantive assignment of error, rendering the State’s motion to dismiss moot

Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause in warrant affidavits)
State v. George, 45 Ohio St.3d 325 (1989) (magistrate must make practical, common-sense probable-cause decision considering informant veracity and basis of knowledge)
State v. Roberts, 110 Ohio St.3d 71 (2006) (standard of appellate review of suppression rulings: accept trial court factual findings, review legal conclusions de novo)
State v. Castagnola, 145 Ohio St.3d 1 (2015) (issues relevant to probable cause: staleness and nexus between alleged crime and place to be searched)
United States v. Carpenter, 360 F.3d 591 (6th Cir. 2004) (nexus requirement: circumstances must indicate why evidence will be found at particular place)
United States v. Washington, 380 F.3d 236 (6th Cir. 2004) (same nexus principles applied to drug investigations)
United States v. Brown, 828 F.3d 375 (6th Cir. 2016) (detective experience and contemporaneous surveillance can help establish nexus)