State v. Diaw

Citations

• 2024 Ohio 2237

Syllabus

The trial court erred by granting Mr. Diaw's motion to suppress. The trial court first erred by finding that a violation of R.C. 2935.23 permitted the suppression of evidence obtained through third-party investigative subpoenas. While the trial court was correct in its determination that the investigative subpoena to Letgo was overly broad, suppression of the evidence was not appropriate as Mr. Diaw had no reasonable expectation of privacy over the information voluntarily disclosed in the investigative subpoenas. Judgment reversed cause remanded.