OH9: Where the car in which defendant was a passenger was going to be inventoried, def’s detention for officer safety was reasonable

The continued detention of the defendant passenger in a car, incidental to the stop of the driver, pending the inventory of the car was reasonable. The trial court resolved a fact dispute and concluded that defendant consented to a search of his person. State v. Starks, 2015-Ohio-2137, 2015 Ohio App. LEXIS 2060 (9th Dist. June 3, 2015).

Three controlled buys from defendant’s house provided probable cause to believe that evidence would be found there. Trial court’s grant of the motion to suppress is reversed. State v. Myers, 2015-Ohio-2135, 2015 Ohio App. LEXIS 2058 (9th Dist. June 3, 2015).*

The trial court found that, under defendant’s version, he wasn’t stopped, and it made no credibility determination at all. Remanded for a consideration of whether he was, in fact, stopped. State v. Williams, 271 Or. App. 481 (June 3, 2015).*