State v. Jordan

Citations

• 145 N.E.3d 357
• 2020 Ohio 689

Syllabus

CONSTITUTIONAL LAW/CRIMINAL – SEARCH AND SEIZURE – PROBABLE CAUSE – ARREST – SENTENCING – CRIM.R. 36: The trial court erred in considering defendant's post-arrest admissions when ruling on defendant's motion to suppress evidence seized pursuant to his arrest, but the error was harmless where the remaining evidence before the court established probable cause that defendant had committed the crime for which he was arrested. Where the trial court announced a three-year driver's license suspension during the sentencing hearing, but the sentencing entry reflected a five-year driver's license suspension, the sentencing entry clearly contained a clerical error for which the proper remedy is to remand the cause to the trial court for a nunc pro tunc entry correcting the license-suspension portion of the sentencing entry pursuant to Crim.R. 36.