State v. Garrett

Citations

• 2018 Ohio 4530
• 123 N.E.3d 327

Syllabus

The trial court did not err in overruling Appellant's motion to suppress drug evidence that officers lawfully observed in plain view. The trial court also did not err in failing to suppress drug evidence found during multiple pat-down searches of Appellant's person, as the pat-down searches were either justified for purposes of officer safety or as a search incident to arrest. The trial court did, however, err in failing to suppress drug evidence that was discovered underneath some junk mail, as that evidence was not in plain view. Judgment affirmed in part, reversed in part, and remanded for further proceedings.