State v. Payne

Citations

• 2023 Ohio 4198

Syllabus

CONSTITUTIONAL LAW/CRIMINAL - FOURTH AMENDMENT - SEARCH AND SEIZURE - AUTOMOBLE EXCEPTION – PROBABLE CAUSE: The trial court did not err in denying defendant's motion to suppress evidence found in his car where, after his car was stopped for two minor traffic offenses, police officers noticed a strong odor of marijuana coming from the car and saw a lottery ticket containing small particles of raw marijuana, and thus, had probable cause to search defendant's vehicle under the automobile exception to the warrant requirement