State v. Toran

Citations

• 237 N.E.3d 39
• 174 Ohio St. 3d 325
• 2023 Ohio 3564

Syllabus

Criminal law—Fourth Amendment to United States Constitution—Warrantless searches—Inventory searches—Government's failure to submit copy of written inventory-search procedure into evidence in support of warrantless inventory search does not render search per se unreasonable—Law-enforcement officer's testimony attributing inventory-search policy to law-enforcement agency that conducted inventory search, explaining when policy must be followed, and explaining whether policy was followed, combined with body-camera footage documenting search, is sufficient evidence to establish existence of such procedure, that officer who conducted search acted in accordance with policy, and that search was reasonable, and therefore lawful, under Fourth Amendment—Court of appeals' judgment reversed and convictions reinstated.