State v. Siegel

Citations

• 180 N.E.3d 574
• 2021 Ohio 4208

Syllabus

PROBABLE CAUSE FOR ISSUANCE OF SEARCH WARRANT-When relying upon the tip of a known informant that is part of the criminal milieu in support of the issuance of a search warrant, an affiant must attest to the informant's veracity, reliability, and basis of knowledge, or must independently corroborate the information provided independent police corroboration of a suspect's address and vehicle does not constitute evidence of drug trafficking the unverified tip of a known, criminal informant coupled only with independent police verification of the suspect's address and vehicle and criminal history consisting of only one drug-related conviction from eight years prior and one pending drug-related charge without any information regarding the basis for the pending charge, did not constitute sufficient probable cause for the issuance of a search warrant for the suspect's residence.