State v. Harris

Citations

• 2023 Ohio 2138

Syllabus

NO-CONTEST PLEA – INVITED ERROR – MOTION TO SUPPRESS – REASONABLE SUSPICION: While defendant's no-contest plea admitted to facts in the complaint and the state's explanation of circumstances that were insufficient to convict defendant for a violation of R.C. 2923.16(E)(1), defendant invited the error when he waived the explanation of circumstances and all defects at the plea hearing, thus barring defendant from challenging his conviction on appeal under the invited-error doctrine. The trial court properly denied defendant's motion to suppress the gun found on defendant because the officer's detention of defendant was supported by reasonable suspicion and the gun was spotted in plain view.