OH2: Looking through a parked car’s windows with a flashlight is not a “search”

Officers looked through defendant’s vehicle windows when it was parked with a flashlight during a nighttime stop, and that wasn’t an unreasonable search. In the vehicle was meth in plain view. State v. Brown, 2019-Ohio-3684, 2019 Ohio App. LEXIS 3766 (2d Dist. Sept. 13, 2019).

The search warrant for defendant’s blood that led to a vehicular homicide case was based on probable cause. State v. Moore, 2019-Ohio-3705, 2019 Ohio App. LEXIS 3781 (6th Dist. Sept. 13, 2019).*