State v. Thomas

Citations

• 2025 Ohio 1516

Syllabus

MOTION TO SUPPRESS – AUTOMOBILE EXCEPTION – OFFICER SAFETY – BRUEN – INEFFECTIVE ASSISTANCE OF COUNSEL: The trial court did not err in denying defendant's motion to suppress evidence discovered during a search of his vehicle during a traffic stop where officers reasonably searched defendant's car to protect officer safety after he was removed from the vehicle based on a suspected firearm. Defendant did not receive ineffective assistance of counsel based on his trial counsel's failure to file a motion to dismiss firearm charges under New York State Rifle & Pistol Assn. v. Bruen, 597 U.S. 1 (2022), where defendant argued it was merely possible, not probable, that such a motion would have changed the outcome of his case.