State v. Groce

Citations

• 2025 Ohio 4345

Syllabus

Because the seizure of a digital video recorder (\DVR\) did not exceed the scope of the authorizing search warrant, defendant's trial counsel had no grounds on which to move to suppress the video evidence contained on the DVR. Defendant, therefore, did not raise any issue in his postconviction petition as to whether his trial counsel was ineffective for failing to move to suppress the video evidence. Accordingly, the trial court did not err in denying defendant's postconviction petition without a hearing.