OH2: The driver matched the description of the owner of the vehicle, so ordering him out was reasonable when a warrant came back for owner

Defendant’s LPN showed that the owner was the same person who had committed criminal trespass. The driver matched the general description of the owner, so that justified getting the driver out. State v. Goines, 2015-Ohio-3505, 2015 Ohio App. LEXIS 3427 (2d Dist. August 28, 2015).

In Florida, the smell of lighter fluid and a Gatorade bottle is part of a meth lab. Officers were at defendant’s property four days earlier searching for a meth lab and had come back. There was a fire burning next to defendant’s truck and a lighter fluid can was in the fire. The officer could smell lighter fluid around defendant’s truck. In the engine compartment the officer could see a Gatorade bottle. Based on past experience, this was probable cause for meth production, and the fire made exigent circumstances. State v. Smith, 2015 Fla. App. LEXIS 12956 (Fla. 1st DCA August 31, 2015).*