Mr. Smith did not provide any form of consent for the corporal to enter the room. Thus, the search of this room violated the Fourth Amendment … the drugs found in the sally port … were also inadmissible as fruit of the poisonous tree.


State v. Smith

2023 – Ohio – 3587

Seventh District Appellate Court

Belmont County, Ohio

September 28, 2023

Allege Rape at the Red Roof Inn in St. Clairsville

This matter originated as an investigation of an alleged rape at a Red Roof Inn in St. Clairsville, Belmont County. The investigation began on March 26, 2019 at the hotel. During this investigation, law enforcement officers discovered evidence which led to the arrest of Mr. Daryl Wayne Smith on criminal drug charges. While Mr. Smith was not ultimately charged with any offense related to the rape or to the drugs that led to his arrest, he was charged with drug-related offenses that occurred after he was transported to the Belmont County Jail.

Deputies responded to the Red Roof Inn Room #116 at 68301 Red Roof Lane, St Clairsville, Ohio on a report of a possible rape.  The events that followed resulted in a narcotics arrest, conviction and appeal.

Appellate Court Describes the Trial Court’s Facts as Misleading

We must note that the facts as described by the state are somewhat misleading and not entirely accurate. The trial court’s decision appears to be based in part on those misleading facts. Although the state contends their encounter with Mr. Smith began when police coincidently encountered Mr. Smith in the lobby of the hotel, and that Mr. Smith then invited the corporal into his hotel room where drugs were lying in plain view, a recording from the corporal’s body camera depicts a substantially different encounter.

Note: The corporal is identified by name in the case, but his name has been redacted in this article.

Red Roof Inn Room #116

The underlying encounter began after a hotel patron or employee reported the possible rape of a woman named Ms. Amber Lopez. Apparently, a hotel employee informed police when they investigated that he saw Ms. Lopez in room 116 at some point. Room 116 was occupied by Mr. Smith. The corporal arrived at the hotel and happened to find Mr. Smith, a person of interest, at the front desk attempting to re-book his room for another night. Mr. Smith was having some difficulty, however, as the room was not originally rented in his name and hotel employees were aware of the pending investigation.

A Nighttime Knock on Door #116

The corporal started the recording on his body camera as he began talking to Mr. Smith. When the video begins, the corporal asks Mr. Smith if he knows the woman who was staying in the room next door. Mr. Smith replies that he did not, but he had encountered her while at the hotel. The corporal informs him that someone at the hotel claimed they saw the woman inside Mr. Smith’s room, however, this person was not sure Mr. Smith was in the room at that time. Mr. Smith explains that the woman knocked on his door the previous night, but he did not allow her inside because she appeared to be intoxicated or under the effect of some drug.

Corporal Begins to Investigate Though the Appellate Court Describes it as ‘Disjointed’

The corporal asks Mr. Smith for his name and driver’s license. Mr. Smith provides his name, but says his license is inside his room. This prompts the corporal to make a series of disjointed but reassuring comments beginning with “look, we are only asking because if something does come up, we don’t think anything is, but since this other girl left last night, we’re just wanting to figure out who was here in case something does come up, you’re not in any trouble. We just want to figure it out that way if we ever run into you again, we probably won’t ever deal with this again.”

Mind if I walk back with you?

After questioning Mr. Smith about the alleged rape victim, the corporal says “look, a detective told me to come up here and talk to you because he didn’t even want to come up that’s how minor that they think it is.” He continues, “if something comes back on this female and she does make a claim that something happened, I don’t want you to be the only one involved.” Mr. Smith responds “well, you got my name.” The corporal again asks Mr. Smith for his driver’s license number and Mr. Smith replies that he does not know it, but ultimately says he will retrieve his license from his room. The corporal asks “do you mind if I just walk back with you?” Mr. Smith agrees, and as they walk alongside a parking lot to access the room the corporal reiterates, “like I said, dude, this is not a big deal.”

The Corporal Walks In

The Admissibility of Evidence is Based on Whether or Not the Corporal had Consent

When they reach Mr. Smith’s room, Mr. Smith slightly opens the door, then stops and asks a woman inside (who was later determined to be Ms. Amber Lopez) “baby, are you decent?” and then “hey, get that little shit cleaned up.” Mr. Smith opens the door just wide enough to allow himself to enter the room by sliding sideways inside and appears to push it shut, as the door begins to return to a closed position. However, the corporal clearly pushes the door wide open (since we can see both of Mr. Smith’s hands and they are not on the door) and he corporal walks into the room uninvited, essentially on Mr. Smith’s heels. Mr. Smith has his back to the door and does not appear to initially realize the corporal has entered the room. As Mr. Smith walks inside, he immediately can be seen looking for his wallet.

Ms. Lopez Motions for the Corporal to Leave

When the door is opened, Ms. Lopez is located at the far side of the room at a sink near the bathroom with her back to the door. The corporal immediately calls Ms. Lopez over to him. Ms. Lopez appears very surprised by the visitor but walks over and attempts to block the corporal from entering further into the room. She appears upset and uncomfortable with his presence inside the room. When he asks to speak with her, she clearly motions outside and requests that they leave the room. The corporal interrupts her and advises her that she is not in any trouble.

Unexpected Menstrual Cycle or Evidence of a Rape?

The corporal then notices a small amount of blood on the bed and Ms. Lopez informs him that her menstruation cycle had unexpectedly started. The corporal says that it could have been from the rape victim, but Ms. Lopez points to her legs (where there is apparently some blood) and the officer laughs. 

Heroin on the Dresser

By this time, Mr. Smith has located his wallet. The corporal looks at his driver’s license and calls into dispatch. Then he pushes past Ms. Lopez, who again tries to block the path along the beds. He walks towards the sink and announces he has found heroin in plain view on a dresser. In order to advance into the room, the corporal bumps Ms. Lopez out of the way. 

Pat Down or Search Incident to Arrest?

At this point, several other deputies arrive at the room. The deputies detain Ms. Lopez, who apparently cannot provide identification. The corporal asks Mr. Smith to wait outside the room. Mr. Smith asks the corporal to hand him his cigarettes, which are on the nightstand closest to the officer. The corporal then finds a baggy containing a pill near the cigarettes. At this point, the corporal says he is detaining Mr. Smith, and he handcuffs him, cuffing Mr. Smith’s hands behind his back. The corporal then searches Mr. Smith’s person, reaching in his pockets and pulling items out.

Can Consent be Obtained After the Search?

The other officers start looking around the room, opening the microwave and opening cabinet doors. The corporal can be seen searching through Ms. Lopez’s purse, where he discovers a digital scale. Again, Ms. Lopez has previously been taken out of the room. After he searches the purse, he informs another officer that he would ask for Ms. Lopez’s consent to search the bag.

Under What Legal Block did the Search of Room #116 Occur?

As the officers continue to search the room, The corporal says “I think we are going to wait until noon and then search the room because it’s in neither one of their names.” The following conversation then occurs between the corporal and an unidentified deputy:

Deputy: As long as your dope is in plain view, you’re good for your search.

The Corporal: The entire room, you think?

Deputy: Yeah.

The Corporal: Because there is going to be, it looks like digital scales.  

Did the Red Roof Inn Management Grant Consent Before Noon?

At the hearing on Mr. Smith’s motion to suppress, the corporal elaborated on his hesitancy regarding the search they had undertaken, stating “the room expired out of their name or out of the other female’s name at noon, and then it would be in the hotel’s possession and they could give us consent [to search] at that time.”

Alleged Rape Occurred in Another Room

The video also reveals that while other officers search the room, the corporal tells them that the blood on the bed might be from the alleged rape. He later states to these officers that it was from the alleged rape victim’s menstrual cycle. However, the officers confirmed the rape they were investigating was alleged to have occurred in another room. 

My Room But Not My Molly

The corporal can be seen leaving the room. Outside, he reads Mr. Smith his Miranda rights and starts questioning him again. The corporal asks Mr. Smith if he used “molly,” stating “it’s not a big deal. I’m not trying to use it against you.” Two deputies then search Mr. Smith, including his socks and shoes, a second time. The corporal tells another officer that Mr. Smith admitted to using “molly.” However, Mr. Smith actually said he thought the drugs found in the room looked like “molly,” but that they did not belong to him.

Investigation Shifts from Rape to Narcotics

Apparently, Ms. Lopez initially gave the police a false name. When she reveals her true identity the corporal becomes very upset, as he recognizes that she is the woman alleged to have been raped. Ms. Lopez explains that she was not raped and did not ask anyone to call the police. Another officer states: “she said she wasn’t raped, that’s good enough for me.” At this point, it is apparent that the officers’ focus had shifted to a narcotics investigation.

Cocaine and Methamphetamine Discovered in the Sallyport

The officers believed the heroin and scale found in the hotel room belonged to Ms. Lopez. However, Mr. Smith was arrested based on the corporal’s belief that the pills in the baggy belonged to him. The record reveals Mr. Smith was searched a third time before being placed in the cruiser. Again, we note Mr. Smith was handcuffed. A separate video admitted into evidence shows the cruiser in which Mr. Smith is riding arrive in the protected jail entrance or “sally port” of the jail and shows Mr. Smith exit the vehicle. Although the video does not show Mr. Smith drop any object as he exists the cruiser, a small object can be seen on the ground after the cruiser leaves the sally port. Later, another officer recovers the object, which officers testified contained methamphetamine and cocaine.

Mr. Smith Goes to a West Virginia Prison

The resulting criminal case has a unique procedural history due to Mr. Smith’s prior incarceration in a West Virginia prison and additional unrelated charges Mr. Smith incurred stemming from actions committed while he waited for trial in this matter.

Mr. Smith is Charged with the Sallyport Cocaine and Methamphetamine

Mr. Smith was not charged with any offense related to the alleged rape or the drugs found inside the hotel room, but on August 7, 2019, Mr. Smith was indicted on one count of aggravated trafficking in drugs, a felony of the third degree in violation of O.R.C. §2925.03(A)(2), (C)(1)(c), and one count of tampering with evidence, a felony of the third degree in violation of O.R.C. §2921.12(A)(1), (B). These charges arose from the drugs found in the sally port. Due to Mr. Smith’s incarceration in West Virginia at the time, he was not arraigned until February 22, 2021. It is unclear when Mr. Smith was released from West Virginia’s custody, however, it appears he had been released prior to this arraignment.

Mr. Smith Finds More Trouble: Protection Order, Assault with a Baseball Bat and More Cocaine

At some time before trial in the instant matter, Mr. Smith was again arrested. Mr. Smith’s girlfriend, S.B., had apparently sought and received a protection order against Mr. Smith in West Virginia but had not informed him of the order. On January 15, 2022, police were called to a local gas station where S.B.’s uncle alleged that Mr. Smith had assaulted him and swung a baseball bat at him. Officers located Mr. Smith asleep at S.B.’s house. While officers retrieved Mr. Smith from the house, they allowed a woman who had exited the house to enter and sit in the backseat of the cruiser without first searching her, despite the fact that S.B.’s residence was known as a drug house. After Mr. Smith was transported to the jail, officers located a baggy of cocaine on the backseat floor.

Mr. Smith is Indicted

On March 3, 2022, more than one year after Mr. Smith’s initial arraignment on the charges arising from the sally port incident, the state filed a superseding indictment which included new charges stemming from the incident at S.B.’s house that occurred while Mr. Smith was waiting for trial.

Superseding Indictment

The superseding indictment contained the following charges: two counts of aggravated trafficking in drugs, a felony of the third degree in violation of O.R.C. §2925.03(A)(2), (C)(1)(c); one count of tampering with evidence, a felony of the third degree in violation of O.R.C. §2921.12(A)(1), (B); possession of cocaine, a felony of the fifth degree in violation of O.R.C. §2925.11(A), (C)(1)(a); and possession of cocaine, a felony of the fourth degree in violation of O.R.C. §2925.11(A), (C)(1)(b). The superseding indictment was filed nineteen days before the scheduled trial date on the charges contained in his first indictment. 

Mr. Smith filed a series of motions to dismiss his charges and the trial court denied his requests.

Mr. Smith is Convicted and Acquitted

Following a two-day trial, a jury found Mr. Smith guilty on one count of tampering with evidence, one count of possession of methamphetamine amounting to more than three grams but less than fifteen grams, and one count of possession of cocaine. Each of these verdicts pertained to the 2019 incident in the sally port. The jury acquitted Mr. Smith of the charges arising from the 2022 incident at S.B.’s house.

Mr. Smith is Sentenced to Seven Years in Prison

On April 5, 2022, the trial court sentenced Mr. Smith to maximum consecutive sentences as follows: thirty-six months of incarceration for tampering, thirty-six months for possession of methamphetamine, and twelve months for possession of cocaine for an aggregate total of eighty-four months, or seven years in prison. The court granted Mr. Smith 137 days of time served.

Mr. Smith Appeals his Convictions based on Unlawful Entry into Room #116

Mr. Smith challenges the court’s denial of his motion to suppress the baggy of drugs found in the sally port following his 2019 arrest. Mr. Smith focuses his arguments on the events that occurred at the hotel, as without the corporal’s unlawful entrance into that room, officers would not have discovered the drugs he is alleged to have dropped at the police department. Thus, his arguments are based on the fruit of the poisonous tree doctrine.

Did the Corporal Have Consent to Enter Room #116?

In response, the state argues that Mr. Smith left the hotel room door open for the corporal, indicating his implied consent. Further, the state points to Mr. Smith’s question posed to his female companion, asking her if she was decent, when he entered the door. The state argues that this suggested Mr. Smith knew the corporal intended to enter the room. Once inside, the state asserts that all evidence was in plain view.

Established Case Law on Consent

Six factors courts consider in determining the voluntariness of consent include: 1) Whether the defendant’s custodial status was voluntary; 2) Whether coercive police procedures were used; 3) The extent and level of the defendant’s cooperation; 4) The defendant’s awareness of his or her right to refuse consent; 5) The defendant’s education and intelligence; and 6) The defendant’s belief that no incriminating evidence would be found. State v. Morris, 2022-Ohio-94, citing State v. George, 2014-Ohio-4853.

Was Consent to Enter Enough to Demonstrate a ‘Preponderance of the Evidence’?

First, we must determine whether the corporal’s entrance into the room was lawful. If it was not, then we undertake an analysis as to whether the drugs which formed the basis for Mr. Smith’s arrest were the fruit of the poisonous tree. If so, then we review whether the drugs were discovered in plain view. “When the prosecution relies upon a consent search theory, it has the burden of establishing that the consent was voluntary by a preponderance of the evidence.” State v. Elliott, 1983 WL 2424, (May 6, 1983), citing Bumper v. North Carolina, 391 U.S. 543 (1968).

Contextual Facts

For context, the entire encounter, beginning with the corporal approaching Mr. Smith in the hotel lobby, must be addressed. The corporal activated his body camera as he spoke to Mr. Smith in the hotel lobby. The corporal asked Mr. Smith his name, which he provided. The corporal then asked for his driver’s license number and after some time, Mr. Smith said he would have to go to his room to retrieve his license. The corporal asked if he could “just walk” with him and Mr. Smith responded in the affirmative.

Did Mr. Smith Provide Implied Consent to Enter?

The corporal concedes that Mr. Smith never expressly invited him inside the room. Instead, he contends Mr. Smith held the door open for him, allowing him to enter. However, this assertion is contrary to the action observed in watching the bodycam video. The focus of this analysis must be on Mr. Smith’s behavior and whether it could be construed to provide the corporal with implied consent to enter the room.

As Mr. Smith opened the door a few inches, he asked Ms. Lopez if she was “decent.” He opened the door only wide enough for him to slide into the room sideways as he spoke to Ms. Lopez. As Mr. Smith entered the room, the door begins closing behind him. However, The corporal then appears to push the door back open, wide, as evidenced by an abrupt change in the direction of the door’s swing. Mr. Smith’s hand is visible, and is at his side. It is clear Mr. Smith did not open the closing door. After pushing the door wide open, the corporal quickly followed Mr. Smith into the room, essentially on his heels. Mr. Smith walked inside with his back to the door and immediately began looking for his wallet.

Although the corporal’s stated purpose for following Mr. Smith to the room was to verify his driver’s license, he immediately ordered Ms. Lopez over to him as he entered. Clearly surprised that the corporal was inside, she nonetheless walked over and he said he needed to speak with her. Ms. Lopez positioned herself in a way to block the corporal from entering the room and gestured towards the door as she told the corporal they could speak outside. However, the corporal interrupted her and assured her that she was not in any trouble. He then bumped her aside and walked past her, all the way to the back of room, where he announced his discovery of heroin on a dresser across the room. Thus, contrary to the state’s arguments, the video evidence reveals Mr. Smith tried to close the door and did not know the corporal entered the room behind him. It is the corporal who opened the door Mr. Smith was closing. Ms. Lopez clearly demonstrated she did not consent to his entrance into the room.

Corporal’s Hesitancy

Significantly, the corporal can be heard during the video, as he and other officers are obviously searching the room, telling the other deputies to wait until noon to begin a search of the room because at that point the hotel was lawfully able to consent to the search. The other deputies opined that no consent was needed because contraband had been found in plain view. The corporal hesitated but eventually agreed to immediately continue with the search. This hesitancy supports that he knew he did not have consent to enter the room in the first place. Otherwise, he would not have been concerned about securing consent from the hotel management.

“[C]lean that little shit up.”

Also relevant to this discussion is Mr. Smith’s instruction to Ms. Lopez to “[C]lean that little shit up.” the corporal said he believed this meant he was permitted to enter the room because the occupants were cleaning before allowing in a guest. However, the corporal gave the woman no time to clean anything before he entered the room. Again, he is clearly seen pushing past Ms. Lopez in her attempt to prevent him from further entering the room. We note that no drugs were found near the room’s entrance. 

Factually Distinguishable Consent Cases

The state cites to several cases, mostly federal, where a suspect opening a door resulted in the determination he or she gave valid consent. However, all of these cases are factually distinguishable from the instant matter. See United States v. Griffin, 530 F.2d 739 (7th Cir.1976) (the Mr. Smith behaved in a manner suggesting he knew he could refuse consent. He then opened the door for law enforcement, stepped back, left the door open, and led the officers inside the room); Robbins v. MacKenzie, 364 F.2d 45 (1st Cir.1966) (the Mr. Smith opened the door, stepped back, and allowed the officers to enter the room); Elliott, supra (the Mr. Smith told officers to “come on in” as he opened the door); State v. Schroeder, No. WD-00-076, 2001 WL 1308002 (Oct. 26, 2001) (officers obtained a search warrant based on an odor of burning marijuana as the door opened); United States v. Turbyfill, 525 F.2d 57 (8th Cir.1975) (a third party opened the door for officers); State v. Asworth, 10th Dist. Franklin No. 90AP-916, 1991 WL 54181 (April 11, 1991) (third party allowed officers inside the room).

Purse Search Evaluated

Aside from the problem of the corporal initial entrance, the video’s depiction of all of the officer’s subsequent behavior is also disturbing. In addition to entering the room without consent, the corporal undertook a search of Ms. Lopez’s purse and found contraband, at the same instant he informed the other officers that he would later ask for her consent to search the bag. Although not at issue, here, the bag was clearly subjected to a search violative of the Fourth Amendment. Neither Ms. Lopez, nor Mr. Smith were located anywhere near the bag. By his comments, the corporal apparently knew he was prohibited from searching the purse absent consent or a warrant. As the officers debated whether they were able to lawfully search the room, they were actively searching the room. The officers can be seen opening doors and rummaging through items. Again, we note that Mr. Smith was never charged with crimes regarding the drugs found in the room, not even the drugs that apparently formed the basis for Mr. Smith’s arrest. This also appears to support a conclusion that the officers knew the search was unlawful.

No Consent Leads to Poisonous Fruit

It is apparent from the video of this matter that Mr. Smith did not provide any form of consent for the corporal to enter the room. Thus, the search of this room violated the Fourth Amendment. But for this search, the officers would not have observed any contraband. As such, we must review whether the drugs found in the sally port, which formed the basis for Mr. Smith’s charges, were also inadmissible as fruit of the poisonous tree.

Conclusion and Holding

At trial, testimony was given that the drugs dropped in the sally port matched the type of drugs found on the hotel nightstand. In addition, the corporal repeatedly told officers at the scene that he believed more drugs might be involved and to make sure both suspects were subjected to a body scan at the jail. Thus, the drugs found in the sally port and attributed to Mr. Smith (which are at issue in this case) were directly related to the unlawful hotel room search. They are a fruit of the poisonous tree. In fact, it is dubious that, but for the unlawful entrance into the room and its search, Mr. Smith would have been taken into custody at all. Mr. Smith’s first assignment of error has merit and is sustained. On remand, all the evidence obtained following the corporal’s entrance into the hotel room and any discussion relating to the unlawful search is to be suppressed as inadmissible.

Information for this article was obtained from State v. Smith, 2023 – Ohio – 3587.

State v. Smith, 2023 – Ohio – 3587 was issued by the Seventh District Appellate Court on September 28, 2023 and is binding in the following Ohio Counties: Belmont, Carroll, Columbiana, Harrison, Jefferson, Mahoning, Monroe and Noble.

Lessons Learned:

  1. Crossing the Threshold – There are three legal ways law enforcement can cross the threshold of a doorway; Consent, Warrant [arrest or search] and an Exigent Circumstance. In this case the Belmont County Prosecutor’s Office argued that the deputy crossed the threshold with Mr. Daryl Wayne Smith consent.  The critical facts are described by the Seventh District Appellate Court as “Mr. Smith opens the door just wide enough to allow himself to enter the room by sliding sideways inside and appears to push it shut, as the door begins to return to a closed position. However, the corporal clearly pushes the door wide open (since we can see both of Mr. Smith’s hands and they are not on the door) and he corporal walks into the room uninvited, essentially on Mr. Smith’s heels. Mr. Smith has his back to the door and does not appear to initially realize the corporal has entered the room. As Mr. Smith walks inside, he immediately can be seen looking for his wallet.”  Smith does not verbally object to the deputy crossing the threshold.  A short time later his co-occupant, Ms. Amber Lopez, requested the deputy leave as described by the court “The corporal immediately calls Ms. Lopez over to him. Ms. Lopez appears very surprised by the visitor but walks over and attempts to block the corporal from entering further into the room. She appears upset and uncomfortable with his presence inside the room. When he asks to speak with her, she clearly motions outside and requests that they leave the room. The corporal interrupts her and advises her that she is not in any trouble.”.  Hereafter the first responding deputy and other deputies that arrived in the interim, searched and discovered a lot of narcotics.
  2. Co-Occupant Conflict – The Seventh District Appellate Court evaluated the deputy’s entry based upon Mr. Smith granting consent. Even assuming that Mr. Smith did grant implied consent by entering Room #116 at the Red Roof Inn by not verbally objecting to the deputy’s entry, Ms. Lopez clearly recanted any consent implied granted by Mr. Smith.  Though the Seventh District Appellate Court did not identify the case by name, the U.S. Supreme Court evaluated a similar situation that occurred in Americus, Georgia on Friday July 6, 2001.  In that case both Mr. and Mrs. Randolph met officers at the threshold of their residential doorway.  Randolph granted verbal consent for Americus Police Officers to enter the home to search for Mr. Randolph’s cocaine.  Mr. Randolph objected to the officer’s entry and specifically told the officers he did not want the officers to enter.  The officers did enter, searched, found the cocaine and charged Mr. Randolph.  The U.S. Supreme Court overturned his conviction as it held “We therefore hold that a warrantless search of a shared dwelling for evidence over the express refusal of consent by a physically present resident cannot be justified as reasonable as to him on the basis of consent given to the police by another resident.” Georgia v. Randolph, 547 U.S. 103 (2006)  In this case, even though it was a hotel room, Ms. Lopez was a lawful co-occupant and had the legal authority to recant Mr. Smith’s consent [if it even existed] for the deputies to enter.  For more information on the Randolph case see: Sometimes Husbands and Wives Disagree … But What is an Officer to do?.
  3. Not Any Fruit – The subsequent search of the hotel room that led to the discovery of the methamphetamine, cocaine and scales were all inadmissible based on the Exclusionary Rule. The Exclusionary Rule has applied to state law enforcement since the Mapp v. Ohio, 367 U.S. 643 (1961).  The Exclusionary Rule Doctrine is often referred to as the Fruit of the Poisonous Tree.  The basic concept is that if any evidence is discovered unlawfully, all of the subsequent evidence found as a result of the first piece of evidence, will also be excluded.  For more on the Exclusionary Rule see: The Road Map(p) to Law Enforcement Training Standards.
  4. Hardest Job In America – In this case the deputies who responded to the rape investigation had some very challenging decisions to make ‘in the moment’. The initial investigation quickly changed from a rape investigation to a narcotics investigation that turned on the crucial element of whether or not the deputy had implied consent to enter Red Roof Inn #116.  Law enforcement is THE hardest job in America and this investigation is reflective as to how difficult law enforcement is each day.

Does your agency train on Crossing the Threshold?

Don’t fail your training.

Don’t let your training fail you!

Be safe, smart and Objectively Reasonable!

Robert H. Meader Esq.