The state showed adequate evidence that it would take 4-5 hours to obtain a search warrant in this case, and that was enough to show exigency here. The defense put on proof that the state could have obtained a telephonic warrant, but there is no requirement that it do so as an alternative to a written warrant, and this court doesn’t impose it here. State v. Gerety, 286 Ore. App. 175, 2017 Ore. App. LEXIS 788 (June 14, 2017).
Defendant’s furtive movements in the car justified his frisk when he was removed from the car. It was immediately apparent the bulge in his pocket was drugs. State v. Billups, 2017-Ohio-4309, 2017 Ohio App. LEXIS 2366 (1st Dist. June 16, 2017).*