State v. Haynes

Citations

• 2018 Ohio 607
• 106 N.E.3d 342

Syllabus

The trial court did not err in overruling the appellant's motion to suppress an incriminating statement he made while being handcuffed after officers found a firearm in a car in which he had been a passenger. The appellant was lawfully detained at all times leading up to his incriminating statement because police were completing an investigation of the driver by confirming her identify and the validity of a warrant for her arrest and arresting her. In addition, a dog's free-air sniff around the driver's car, which occurred contemporaneously with her arrest, gave police probable cause to search the car. The search resulted in the discovery of the loaded handgun, which the appellant promptly admitted owning. Although the appellant had not been Mirandized when he made the admission, it was not the product of police \interrogation.\ Judgment affirmed. (Froelich, J., dissenting.)