State v. Atkinson

Citations

• 2021 Ohio 3844

Syllabus

The trial court did not err in overruling appellant's motion to suppress. After a valid traffic stop for no headlights and taillights, and after learning that appellant lacked a valid driver's license and that her vehicle had fictitious plates, the vehicle was lawfully towed from the \trafficway.\ Having been lawfully impounded, and pursuant to Sheriff's Office policy, the vehicle was subject to an inventory search, which included the locked glove box, the key to which was in appellant's possession. Since deputies had probable cause to arrest appellant, the \threat\ to place her in handcuffs in order obtain the key to the glove box cannot be characterized as coercive. Judgment affirmed.