State v. Collins

Citations

• 2022 Ohio 4353

Syllabus

MOTION TO SUPPRESS — CONSENSUAL ENCOUNTER — CARRYING A CONCEALED WEAPON — IMPROPER HANDLING — WEAPONS — ALLIED OFFENSES – R.C. 2941.25: The trial court properly denied defendant's motion to suppress because the police officer's approach and questioning of defendant, who was seated in a parked vehicle, was a consensual encounter that did not require reasonable suspicion of criminal activity. Where defendant had a loaded firearm under his seat in a vehicle, the trial court erred by sentencing defendant for the offenses of carrying a concealed weapon and improper handling of a firearm in a motor vehicle because, under the facts of the case, the offenses were not dissimilar in import, were not committed separately, and were not committed with a separate animus.