State v. Landrum

Citations

• 2018 Ohio 4582

Syllabus

SEARCH AND SEIZURE – COMMON AUTHORITY – APPARENT AUTHORITY : The trial court erred in overruling defendant's motion to suppress evidence obtained during a warrantless search of his bedroom after probation officers entered the home he shared with a probationer, searched his bedroom, and found cocaine, where the state failed to prove that the probationer had joint access or control over the bedroom, such that the probationer had common authority or apparent authority over the bedroom to consent to the search.