State v. Seem

Citations

• 196 N.E.3d 384
• 2022 Ohio 3507

Syllabus

Trial court erred in denying motion to suppress evidence taken from seized cellphone. State failed to show that an exception to warrant requirement justified warrantless seizure of cellphone. Appellant's consent to search of phone was premised on his acquiescence to officer's claim of lawful authority to immediately seize phone. Exigency exception did not apply because state failed to articulate probable cause for seizing phone.