OH last week

The marijuana residue on defendant’s shirt when he was ordered out of the car during a stop was in plain view. The court requires exigent circumstances, too, to search the car, and it found it from the stop being at 2:30 am. State v. Willette, 2012 Ohio 3836, 2012 Ohio App. LEXIS 3386 (4th Dist. August 22, 2012).*

When the car was stopped, the defendant’s movements in the car justified a frisk of him and the car for weapons. This was not a Gant search incident. City of Euclid v. Hull, 2012 Ohio 3801, 2012 Ohio App. LEXIS 3359 (8th Dist. August 23, 2012).*

Officers investigating a home invasion went to the basement to find a cage for a small dog that would be left behind when they left the house. They found marijuana. The entry to the basement was reasonable and not a pretext for further search. State v. Rivera, 2012 Ohio 3755, 2012 Ohio App. LEXIS 3313 (12th Dist. August 20, 2012).*

A motion to suppress a search warrant tolls speedy trial. State v. Hoang, 2012 Ohio 3741, 2012 Ohio App. LEXIS 3308 (9th Dist. August 20, 2012).*

Crossing the centerline is reason for a traffic stop. State v. McCandlish, 2012 Ohio 3765, 2012 Ohio App. LEXIS 3337 (10th Dist. August 21, 2012).*

Defendant was stopped for matching the clothing description after an aggravated burglary, and it was reasonable. State v. Garrison, 2012 Ohio 3846, 2012 Ohio App. LEXIS 3397 (2d Dist. August 24, 2012).*