State v. Pitts

Citations

• 2020 Ohio 2655

Syllabus

Appellant's general assertions that the affiant in a search warrant application was lying does not constitute a substantial preliminary showing of a false statement so as to require a Franks hearing. Appellant is not entitled to disclosure of confidential informants where their testimony is not vital to establishing any of the elements of the crimes and appellant's defense is not prejudiced. Appellant is not entitled to the return of seized property that is subject to civil forfeiture proceedings.