Defendant was arrested outside a store for shoplifting a belt and hat he wore out of the store. The backpack he was wearing was subject to search incident under Gant when he was arrested. State v. Whipple, 2017-Ohio-1094, 2017 Ohio App. LEXIS 1077 (12th Dist. March 27, 2017).
The officer had reasonable suspicion for encountering defendant at a gas station where he was parked getting gas. His DL was suspended, and he was first inside and came out to the car where there was a passenger in the car. He said the passenger was driving off from there. That was reasonable suspicion that he’d driven there under suspicion. The reasonable suspicion supported the delay for the dog sniff. State v. Crouse, 2017-Ohio-1097, 2017 Ohio App. LEXIS 1081 (5th Dist. March 24, 2017).*