State v. Johnson

Citations

• 2022 Ohio 1733

Syllabus

In a case involving a challenge to the scope of an inventory search of an impounded automobile following the lawful arrest of the driver, where police officers conducted the inventory search in compliance with the police department's reasonable standardized policy, and because they limited that search to \reasonable accessible areas\ as set forth in that policy, the officers did not exceed the scope of a lawful inventory search. We reach this conclusion even if the officers may also have had an investigative motive when they conducted the inventory search. Consequently, the trial court erred when it suppressed the evidence discovered in the inventory search and the subsequent investigative search.