OH5: RS for drugs means likely guns, so ability to frisk automatic

“The Ohio Supreme Court has stated that ‘the right to frisk is virtually automatic when individuals are suspected of committing a crime, like drug trafficking, for which they are likely to be armed.’ Evans at ¶ 9. Further, ‘[r]ecognizing the prevalence of weapons in places where illegal drugs are sold and used … an officer’s fear of violence when investigating drug activity is a legitimate concern that will justify a pat-down search for weapons.’ Martin, supra, 2004-Ohio-2738 at ¶ 17 …. In the instant case, the justification for the pat-down was twofold: appellant had just been involved in a narcotics transaction and she admitted to the detective that she had a syringe stuffed down her pants, a potential risk to anyone she encountered.” State v. Wiegand, 2017-Ohio-9143, 2017 Ohio App. LEXIS 5588 (5th Dist. Dec. 18, 2017).