State v. Jones

{¶ 1} “Totality of the circumstances” is the proper standard of review to determine whether probable cause exists to issue a search warrant if the supporting affidavit relies in part on evidence seized from a “trash pull.” Using *267the totality-of-the-circumstances test in this case, we hold that the evidence seized from a single trash pull that corroborates tips and background information involving drug activity is sufficient to establish probable cause for a warrant. Accordingly, the evidence should not have been suppressed in this case, and we reverse the judgment of the court of appeals and…