OH11: Getting beat up in a bar fight permits a community caretaking search of your person

Defendant was beat up in a bar fight. He bled all over his shirt and his jaw was swollen. He rejected efforts for medical help, but the officer’s stop of him was reasonable under the community caretaking function. That community caretaking function search [somehow reasonably] included removing contraband from him. State v. Crayton, 2017-Ohio-705, 2017 Ohio App. LEXIS 694 (11th Dist. Feb. 27, 2017). [I still can’t justify this one under any reasonable reading of the law. Protect you from yourself?]

Defendant was a passenger in a stopped rental car, and it was apparent to the officer that the two in the car were lying about what was up and where they were going. By the time the drug dog arrived, the officer completed the initial checks, and the officer didn’t do anything really to extend the stop unreasonably. United States v. Angulo, 2017 U.S. Dist. LEXIS 25098 (D.N.J. Feb. 22, 2017).*

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