With probable cause to believe that a vehicle has evidence in it, the automobile exception allows entry into a locked container (here a locked box) inside the vehicle. Also, a police officer following a car is not a seizure. United States v. Hylmon, 2019 U.S. Dist. LEXIS 141210 (E.D. Tenn. June 26, 2019), adopted, 2019 U.S. Dist. LEXIS 140572 (E.D. Tenn. Aug. 20, 2019).
The video of the traffic stop does not undermine the findings of fact that the state trooper testified that he could smell marijuana in the case. A subsequent search of the passenger compartment turned up none except for an Oxy pill. The search of defendant’s person thereafter turned up more pills. The searches were valid. State v. Farrow, 2019-Ohio-3311, 2019 Ohio App. LEXIS 3399 (9th Dist. Aug. 19, 2019).*