It was reasonable for the officers to conclude that because the person stopped coming home was a drug offender, so were the people he was living with. “Notwithstanding the trial court’s conclusion [of protective sweep], we conclude that, based on the totality of the circumstances of this case, exigent circumstances existed to justify the warrantless entry and limited search of the residence because competent, credible evidence exists in the record reflecting that it was reasonable for law enforcement to believe that the drug evidence was at risk of being destroyed if the officers did not immediately enter to secure the scene. See King, 563 U.S. at 457; Benvenuto, 2018-Ohio-2242, at ¶ 25; Johnson, 457 Fed.Appx. at 515; United States v. Waide, E.D.Ky CR No. 5:18-116-KKC, 2019 U.S. Dist. LEXIS 60014, 2019 WL 1521973, *7 (Apr. 8, 2019).” State v. Reilly, 2020-Ohio-850, 2020 Ohio App. LEXIS 777 (3d Dist. Mar. 9, 2020).
There was probable cause for a search warrant for a surveillance DVR on property adjoining defendant’s as to what it could have seen [and there is no discussion of standing]. United States v. Waide, 2019 U.S. Dist. LEXIS 60014 (E.D. Ky. Apr. 9, 2019).*Deception to get defendant to come back to the courthouse to ask him about his phone and then for consent to search it didn’t void the consent.