State v. Sullivan

Citations

• 2019 Ohio 2279

Syllabus

A defendant appeals the common pleas court's decision denying his motion to suppress evidence of narcotics recovered during traffic stop. A K9 drug sniff led to police uncovering narcotics in the vehicle stored in a locked tool box. The weight of the evidence supported the trial court's findings that the defendant's vehicle rolled through a stop sign, justifying the traffic stop, and that the K9 \indicated\ the odor of narcotics. The arresting officer testified that he observed the traffic violation, which was confirmed by dash-camera video. The K9 officer testified as to observing the K9 indicate, which was indirectly corroborated by the dash-camera video. Police were permitted to search the defendant's vehicle without a warrant based upon probable cause established by the positive K9 drug sniff and the officer's background knowledge of the defendant's suspected drug activity. The search of the locked tool box was proper as police had the right to search any part of the vehicle that may conceal suspected narcotics.