State v. Eads

Citations

• 154 N.E.3d 538
• 2020 Ohio 2805

Syllabus

CONSTITUTIONAL LAW/CRIMINAL — FOURTH AMENDMENT — SEARCH AND SEIZURE — WARRANT REQUIREMENT — GOOD-FAITH EXCEPTION — OVI: The trial court did not err in denying defendant's motion to suppress medical records containing alcohol- and drug-test results, created for medical purposes during emergency treatment of defendant, even though the law enforcement officer's warrantless acquisition of the records during an OVI investigation violated the defendant's Fourth Amendment rights, because, considering the state of the law in 2017, it was objectively reasonable for the officer to rely on a now-revised departmental policy implementing a procedure set forth in R.C. 2317.02(B)(2)(a) and 2317.022 for obtaining these records from the health care provider without a warrant, and therefore, the good-faith exception protected the evidence from the exclusionary rule.