State v. Jackson

Citations

• 2024 Ohio 4770

Syllabus

SEARCH AND SEIZURE – WEAPONS : The trial court did not err by suppressing evidence of firearms where officers did not have probable cause or reasonable suspicion to stop Defendants' vehicle and to effectuate a felony arrest because Defendants did not obstruct official business by driving away from officers without being commanded to stop and because the circumstances otherwise did not constitute reasonable suspicion of criminal activity. [See CONCURRENCE: The inevitable discovery doctrine may have rendered the warrantless search of guns found in plain view in the backseat of a car reasonable under the Fourth Amendment had the State preserved it for appellate review.] [But See DISSENT: The police had a reasonable suspicion of criminal activity that justified an investigative stop where the officers had been informed earlier in the day that shots had been fired on the same street as the stop and that tensions were rising between groups of juveniles, it was in a high-crime area, it was rainy and dark when the officers approached the car with tinted windows preventing them from seeing inside, and defendants made furtive movements before fleeing the scene.]