State v. Tolbert

Citations

• 2025 Ohio 4469

Syllabus

Motion to suppress; search warrant; warrant affidavit; probable cause; Franks v. Delaware; Franks hearing; false statements; omissions; undisclosed inferences. Reversed and remanded. The trial court did not determine, pursuant to Franks v. Delaware, whether the warrant affidavit contained intentionally false statements or false statements with reckless disregard for the truth, nor did the trial court determine whether the search warrant affidavit's remaining content is sufficient to establish probable cause. The trial court also did not determine whether any significant undisclosed inferences were made in the search warrant affidavit.