State v. Lewis

Citations

• 224 N.E.3d 57
• 2023 Ohio 3036

Syllabus

CONSTITUTIONAL LAW/CRIMINAL — SEARCH AND SEIZURE —FOURTH AMENDMENT — AUTOMOBILE EXCEPTION — WARRANTLESS SEARCH: The trial court erred when it denied defendant's motion to suppress the evidence recovered from a warrantless search of her purse because the automobile exception to the Fourth Amendment's warrant requirement did not apply where defendant exited from the vehicle with her purse before officers developed probable cause under the automobile exception to search the vehicle and any containers within the passenger compartment.