State v. Donaldson

Citations

• 2019 Ohio 232

Syllabus

Evidence found pursuant to a warrantless search of appellant's vehicle was not subject to suppression under the automobile exception, where the police officer testified that he detected a very strong odor of raw marijuana upon approaching the vehicle and appellant acknowledged that he was in possession of marijuana. The permissible scope of the search extended into the trunk of the vehicle because the officer smelled raw, rather than burnt, marijuana.