State v. Woods

Citations

• 2026 Ohio 1204

Syllabus

Motion to suppress; warrantless search; Fourth Amendment; unreasonable search and seizure; voluntary consent; implied consent; protective sweep; totality of the circumstances; Maryland v. Buie, 494 U.S. 325 (1990). Judgment affirmed. The trial court did not err in granting defendant's motion to suppress evidence of a firearm confiscated during an alleged protective sweep of his apartment. Without consent to enter other areas of the apartment, and without a reason to believe that their safety was at risk, the police officers could not and did not need to conduct a protective sweep of the bedroom where they discovered the firearm. Thus, defendant's constitutional rights were violated.