State v. Boyd

Citations

• 2020 Ohio 125

Syllabus

A detective did not conduct a search implicating the Fourth Amendment when he looked into appellant's vehicle located in a store's parking lot. The detective, while looking into the vehicle, observed what he immediately recognized as probable cocaine. This plain view discovery allowed the detective to conduct a warrantless seizure of the probable contraband which, upon testing, was confirmed to be cocaine. Additionally, the trial court reasonably concluded that the tow was necessary in order to avoid either theft or vandalism since the subject vehicle, which was parked in private business lot, could readily be placed in safekeeping in a police-controlled lot. The trial court properly overruled appellant's motion to suppress. Judgment affirmed.