"Abandoned" Hard Drives and "Search Warrants"

On January 17, 2012, the Ohio Supreme Court held that if a defendant abandons a computer hard drive, the police do not need to obtain a search warrant to search that hard drive.  In State v. Gould, the Court noted that the defendant had left his computer hard drive with his mother for months, and had left the State.   In light of these circumstances, the Court held that the hard drive had been "abandoned," and that police do not need to obtain a search warrant to search abandoned property.   The hard drive contained a number of child pornography images.