When the state relies on inventory to justify a search of a car, it has to put on proof that the inventory policy was followed and that it was done in good faith. State v. Beasley, 2019-Ohio-3936, 2019 Ohio App. LEXIS 4017 (1st Dist. Sept. 27, 2019).
The state failed to put on proof at the suppression hearing that the officer had an objective belief defendant was intentionally avoiding arrest. The state also failed to show the officer had a reasonable suspicion defendant was armed. Thus, the frisk after the arrest was illegal. Goodman v. State, 2019 Fla. App. LEXIS 14644 (Fla. 2d DCA Sept. 27, 2019).*