OH5: Def’s large knife on his belt justified patdown for additional weapons

“We concur with the trial court that Officer Sholl had a sufficient reasonable objective basis under the totality of the circumstances to frisk appellant for weapons. Appellant had a large fixed blade knife on his belt loop. A pat down for additional weapons was warranted. When asked if he had any additional weapons on his person, appellant was untruthful. It was reasonable for Officer Sholl to ask appellant what was inside the black pouch as it could have contained razor blades or a folded knife. Appellant volunteered that the pouch contained methamphetamine.” State v. Wheeler, 2020-Ohio-6720, 2020 Ohio App. LEXIS 4561 (5th Dist. Dec. 15, 2020).

“Probable cause only requires ‘a fair probability that contraband or evidence of a crime will be found.’ … By the time they surrounded the truck, the officers had a tip from a reliable informant that individuals in the truck were about to complete a drug sale and that they had drugs in the truck. No more was needed to justify the seizure of Garcia and the driver and the subsequent K-9 inspection.” United States v. Garcia, 2020 U.S. App. LEXIS 39529 (1st Cir. Dec. 16, 2020).*