State v. Warnick

Citations

• 2020 Ohio 4240

Syllabus

The trial court did not err in denying appellant's motion to suppress. Troopers reasonably detained appellant based on reasonable concerns that he was impaired or in need of emergency care and that his vehicle was unsafe to drive. Trooper lawfully requested appellant to exit his vehicle, conducted a pat down for weapons, and placed appellant in his cruiser for additional questioning. Second trooper's observation of a drug pipe, white crystal substance, and ammunition in plain view, along with appellant's admission that he had a firearm in the vehicle, justified the trooper's entry into the vehicle. Troopers were not required to inform appellant of his Miranda rights during the investigatory detention. Judgment affirmed.