State v. Bradley

Citations

• 2025 Ohio 58

Syllabus

Deputies observed a stolen automobile on appellant's property using a drone on public property and adjoining private property. Without obtaining a warrant, deputies then entered appellant's property to arrest him and seize the vehicle, at which time they found other stolen property on the premises. The trial court found that the warrantless entry had violated the Fourth Amendment and suppressed evidence of the stolen property discovered after the deputies' entry. But based on the independent source doctrine, the trial court concluded that the seizure of the stolen automobile had not been unconstitutional and that use of a drone flying over adjacent property had not violated the Fourth Amendment. The trial court correctly concluded that probable cause to seize the automobile had been obtained through a source (the drone surveillance) that was independent from the illegal entry and that suppression of the automobile was not warranted. Judgment affirmed.