OH2: Officer’s asking for consent to search before inventory doesn’t make it pretextual

“Although Officer Lindsey asked White if he (the officer) could search the vehicle prior to deciding to tow the vehicle, that question alone did not require a conclusion that the subsequent inventory search was pretextual. The Dayton Police Department tow policy authorized the inventory search under the circumstances in this case, and the evidence demonstrated that Officer Gianangeli complied with that policy when she conducted the inventory search.” State v. White, 2020-Ohio-5544, 2020 Ohio App. LEXIS 4406 (2d Dist. Dec. 4, 2020).

Defendant crossed the centerline making a left turn. His excuse that the snow caused him to do it isn’t credited. United States v. Bare, 2020 U.S. App. LEXIS 37805 (4th Cir. Dec. 3, 2020).*

There were enough connections to defendant’s premises to show nexus. And, even if not, the officers still acted in good faith. United States v. Dear, 2020 U.S. Dist. LEXIS 227017 (D.Conn. Dec. 3, 2020).*