State v. Adams

Citations

• 2017 Ohio 7186

Syllabus

Trial court did not err by denying appellant's motion to suppress evidence uncovered in the warrantless search of his vehicle. Under the collective knowledge doctrine, a uniformed officer who received a radio call from an undercover officer informing him that appellant had committed an illegal U-turn was competent to testify about the factual basis for the subsequent traffic stop even though he did not witness the violation. Because a reasonable suspicion that appellant had just completed an illegal drug transaction arose during a lawful traffic stop, appellant's extended detention in order for a K-9 unit to conduct a sweep of appellant's vehicle did not violate the Fourth Amendment. Judgment affirmed.