State v. Sadler

2025 Ohio 4665

• Court: Ohio Court of Appeals
• Decided: October 9, 2025
• Docket: 2025-CA-00029
• Status: Published

Opinion

[Cite as State v. Sadler, 2025-Ohio-4665.]

COURT OF APPEALS LICKING COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO Case No. 2025-CA-00029

Plaintiff - Appellee Opinion And Judgment Entry

-vs- Appeal from the Court of Common Pleas, Case No. 2024-CR-00743 ALVIN SADLER III Judgment: Affirmed Defendant – Appellant Date of Judgment Entry: October 9, 2025

BEFORE: Andrew J. King; Robert G. Montgomery; David M. Gormley, Appellate Judges

APPEARANCES: KENNETH W. OSWALT, for Plaintiff-Appellee; CHRIS BRIGDON, for Defendant-Appellant.

King, J.

{¶ 1} Defendant-Appellant Alvin Sadler appeals the March 21, 2025 judgment of

the Licking County Court of Common Pleas which overruled his motion to suppress.

Plaintiff-Appellee is the State of Ohio. We affirm the trial court.

Facts and Procedural History

{¶ 2} In June of 2024, Detective Jarrod Conley of the Newark Police Department

was working with the Central Ohio Drug Enforcement Agency (CODE) and assigned to a

drug investigation involving Sadler. In August 2024, an anticipatory affidavit and warrant

to search Sadler's residence was drafted, however, additional information further

prolonged the investigation. The final line of the anticipatory affidavit read "Sworn to and

subscribed in my presence this ____ day of August 2024. Time ___." The warrant also contained a partially pre-filled date line which read "Dated this ____ day of August 2024.

Time _____." State's Exhibit 1.

{¶ 3} On October 21, 2024, Conley learned Sadler took possession of a large

amount of methamphetamine and was storing it inside his residence on Valley View Drive

Southeast. On the same day Conley went to Licking County Common Pleas Court Judge

Branstool requesting a warrant to search Sadler's residence and using the previously

drafted affidavit and warrant. The affidavit described information received by CODE

detectives on October 15 and 21, 2024. Conley forgot, however, to change the month on

the pre-drafted documents from August to October and no one caught the error. The

signed affidavit therefore read "Sworn to and subscribed in my presence this 21st day of

August 2024. Time 9:21 am." The warrant contained the same date and time. The warrant

return and inventory, however, listed the correct month of October. State's exhibits 1 and

2. The search of Sadler's residence yielded more than five times the bulk amount of

methamphetamine.

{¶ 4} As a result of the search, on October 31, 2024, the Licking County Grand

Jury returned an indictment charging Sadler with one count each of aggravated

possession of drugs and aggravated trafficking in drugs, felonies of the second degree,

and one count of having weapons under disability, a felony of the third degree.

{¶ 5} On November 24, 2024, Sadler filed a motion to suppress all evidence

obtained in the search. Seizing on the typographical error, Sadler argued the two-month

delay in serving the warrant was a violation of Crim.R. 41(C)(2), constituted grossly

negligent conduct, rendered the warrant invalid, and therefore precluded any application

of the good faith exception. In its memorandum contra, the State argued the word August in the affidavit and search warrant was a scrivener's error, did not amount to a

constitutional violation, and that the officers reasonably relied on the warrant.

{¶ 6} A suppression hearing was held on January 13, 2025. The State elicited the

above outlined testimony from Detective Conley and additionally submitted body camera

footage of the officers executing the search warrant on October 21, 2024. State's exhibit

3. Sadler presented no evidence.

{¶ 7} By judgment entry issued March 21, 2025, the trial court overruled Sadler's

motion finding no deliberate, reckless, or grossly negligent police conduct, and thus no

constitutional violation sufficient to warrant suppression. Sadler subsequently withdrew

his pleas of not guilty and entered pleas of no contest. The trial court accepted Sadler's

pleas, found him guilty, and imposed an aggregate prison term of four years.

{¶ 8} Sadler filed an appeal and the matter is now before this court for

consideration. He raises one assignment of error as follows:

I

{¶ 9} "THE TRIAL COURT ABUSED ITS DISCRETION IN OVERRULING THE

DEFENDANT'S MOTION TO SUPPRESS EVIDENCE OBTAINED FROM A SEARCH

WARRANT EXECUTED ON OCTOBER 21, 2024, WHERE THE WARRANT AND

AFFIDAVIT WERE DATED AUGUST 21, 2024, IN VIOLATION OF OHIO CRIMINAL

RULE 41(C)(2), CONSTITUTING A SUBSTANTIVE FOURTH AMENDMENT

VIOLATION NOT SUBJECT TO THE GOOD FAITH EXCEPTION, AND WHERE

SYSTEMIC NEGLIGENCE IN THE PREPARATION AND REVIEW OF THE WARRANT

WARRANTED SUPPRESSION TO DETER FUTURE MISCONDUCT." {¶ 10} In his sole assignment of error, Sadler argues the trial court erred in

overruling his motion to suppress. We disagree.

Standard of Review

{¶ 11} Appellate review of a trial court's decision to deny a motion to suppress

involves a mixed question of law and fact. State v. Long, 127 Ohio App.3d 328, 332, (4th

Dist.1998). During a suppression hearing, the trial court assumes the role of trier of fact

and, as such, is in the best position to resolve questions of fact and to evaluate witness

credibility. State v. Brooks, 75 Ohio St.3d 148, 154 (1996). A reviewing court is bound to

accept the trial court's findings of fact if they are supported by competent, credible

evidence. State v. Medcalf, 111 Ohio App.3d 142, 145 (4th Dist.1996). Accepting these

facts as true, the appellate court must independently determine as a matter of law, without

deference to the trial court's conclusion, whether the trial court's decision meets the

applicable legal standard. State v. Williams, 86 Ohio App.3d 37, 42 (4th Dist.1993),

overruled on other grounds.

Sadler's Arguments

{¶ 12} Sadler appears to challenge the trial court's finding of fact. He argues the

trial court erred in accepting the State's claim that the August date on the affidavit and

search warrant "was a mere scrivener's error" when the warrant was not executed until

October. Brief of Appellant at 4. He argues this defect in the search warrant and affidavit

violated the mandate of Crim.R. 41(C)(2) that a warrant be executed within three days.

According to Sadler, this defect constitutes systemic negligence precluding the good faith

exception. {¶ 13} First, it is well-established that the exclusionary rule is inapplicable to

technical violations of Crim.R. 41 which do not rise to the level of constitutional error.

Cleveland v. Becvar, 63 Ohio App.3d 163, 166 (8th Dist.1989).

{¶ 14} Next, Sadler challenges the information contained in the affidavit as "stale"

based on the August date contained in the signature lines. The evidence presented at the

suppression hearing, however, supports the trial court's conclusion that the date error

was a technical defect which did not call for application of the exclusionary rule. First, the

affidavit described information obtained by CODE officers on October 15 and 21, 2024,

not August. State's Exhibit 1, Affidavit for Search, ¶¶ 3-4. Second, the warrant was

executed the same day it was requested—October 21, 2024—as evidenced by body

camera footage submitted by the State during the suppression hearing and Detective

Conley's testimony. State's Exhibit 3, transcript of suppression hearing at 21. Sadler's

staleness arguments are therefore unsupported by the record.

{¶ 15} In State v. Newman, 2017-Ohio-4047 (5th Dist.), we noted "it is well-

established that inadvertent clerical errors, unless they cause prejudice to the defendant,

will not invalidate an otherwise valid search warrant." Id. at ¶ 22. Application of the

exclusionary rule is meant to deter law enforcement conduct that "flagrantly, deliberately,

or recklessly violates the Fourth Amendment." State v. Hoffman, 2014-Ohio-4795, ¶ 46.

The record before us contains no evidence of any such conduct. Rather, the warrant

contained a technical violation which did not rise to the level of constitutional error.

Accordingly, Sadler's sole assignment of error is overruled. {¶ 16} For the reasons stated in our accompanying Opinion, the judgment of the

Licking County Court of Common Pleas is affirmed.

{¶ 17} Costs to Appellant.

By: King, P.J.

Montgomery, J. and

Gormley, J. concur.