State v. Martin

Citations

• 2024 Ohio 10

Syllabus

MOTION TO SUPPRESS — CONSTITUTIONAL LAW —FOURTH AMENDMENT — SEARCH AND SEIZURE — PROBABLE CAUSE — AUTOMOBILE EXCEPTION — ALLIED OFFENSES: The trial court did not err in denying defendant's motion to suppress physical evidence found in his car where investigators intercepted a jail call instructing defendant to go to a specific location to retrieve contraband and police witnessed defendant at that location on the same day and leaving with a bookbag. Officers had probable cause to stop defendant and perform a warrantless search of his vehicle under the automobile exception where officers had reasonable grounds to believe there was contraband in the vehicle. The trial court committed plain error in failing to merge defendant's convictions for possessing marijuana and trafficking in marijuana.