State v. Gray

Citations

• 208 N.E.3d 216
• 2023 Ohio 338

Syllabus

The trial court did not err in denying appellant's motion to suppress the evidence found in the trunk of his car where officers had probable cause to search the trunk of the car based on the facts known at the time of the search and a canine's positive alert to the presence of narcotics. The trial court also did not err in finding that appellant's initial Miranda warnings remained effective throughout the duration of a short transport to the police station and throughout the duration of a custodial interview. Appellant did not receive ineffective assistance of counsel where counsel failed to subpoena a witness whose testimony was entirely speculative and whose testimony would not have significantly assisted appellant's defense. Counsel was also not ineffective for failing to object to highly probative evidence. While the trial court did err in imposing consecutive indefinite prison terms, the error did not rise to the level of plain error, as the calculation of the prison sentence did not affect appellant's substantial rights.