Ohio statute states that a methamphetamine lab is per se an exigency, and the officer’s seizure without a search warrant to get a search warrant was reasonable. State v. Umstead, 2017-Ohio-698, 2017 Ohio App. LEXIS 691 (5th Dist. Feb. 24, 2017).
Defendant’s stop was proper based on window tint and then there was the faint smell of marijuana which then gave probable cause for a search of the car. State v. Davenport, 2017-Ohio-688, 2017 Ohio App. LEXIS 706 (2d Dist. Feb. 24, 2017).*
The passenger’s movements in lifting his butt up in the seat was enough to order him out of the car. He was acting like he was hiding something. He was handcuffed and drugs fell out of his pantleg. State v. Orosz, 2017-Ohio-707, 2017 Ohio App. LEXIS 700 (11th Dist. Feb. 27, 2017).*