State v. Madaris

Citations

• 2026 Ohio 2305

Syllabus

CONSTITUTIONAL LAW/CRIMINAL — SEARCH AND SEIZURE — SEARCH WARRANT — MOTION TO SUPPRESS — GOOD-FAITH EXCEPTION — EVIDENCE — CONSTRUCTIVE POSSESSION — POSSESSION OF DRUGS — SUFFICIENCY — MANIFEST WEIGHT— INEFFECTIVE ASSISTANCE OF COUNSEL: The trial court did not err in overruling defendant's motion to suppress evidence found in the residence pursuant to the search warrant because the affidavit provided a minimally sufficient nexus between the offenses under investigation and the need to search the home, and the officers acted in good-faith reliance on the warrant. The trial court did not err by admitting two text messages referencing a drug transaction sent to defendant during the execution of the search warrant because the evidence directly proved that defendant had the intent and knowledge to sell the drugs he possessed on that day, a necessary element to establish the charged offenses. Any error by the trial court in admitting two text messages referencing drug transactions sent close in time to the charged offense was harmless because defendant was acquitted of the trafficking charges. Defendant's convictions for possession of a fentanyl-related compound and aggravated possession of drugs were supported by sufficient evidence and not against the weight of the evidence where the State proved defendant constructively possessed the drugs where the evidence established defendant regularly slept at the residence, he was the sole occupant of the residence when the warrant was executed, some of the drugs were found in plain view in the bedroom, he was in the bedroom when the search was initiated, his clothing and boots were in the bedroom, and text messages revealed that defendant intended to sell drugs that morning. Defendant's trial counsel did not provide ineffective assistance of counsel because counsel's questioning of the lead detective was trial strategy designed to undermine the credibility of the lead investigator, the investigation, and the lack of evidence of