In re L.S., 2016 Ohio 5582

Police initiated a high-speed traffic stop after a vehicle ran a stop sign, sped up when lights/siren were activated, ran a red light, and crashed while attempting to evade interception.
Officers approached the stopped car with guns drawn; L.S. was the front-seat passenger and had a book bag at his feet.
Officers ordered L.S. to keep his hands visible and not touch the bag; L.S. reached for and told officers he was taking the bag and acknowledged ownership.
Occupants were detained, the vehicle was towed, and officers opened the bag and discovered a loaded firearm.
L.S. moved to suppress the firearm evidence (arguing a Fourth Amendment violation) and was adjudicated delinquent after a bench trial; he also challenged being physically restrained at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was opening L.S.’s closed bag a Fourth Amendment violation?	L.S.: opening the bag required a written/established policy for opening closed containers during inventory searches; none was shown.	State: search was justified as an inventory of a towed vehicle and, alternatively, under the automobile exception because officers had probable cause.	Held: Inventory exception did not apply (no policy for opening containers), but automobile exception justified the search — suppression denied.
Did the court err by shackling L.S. during trial?	L.S.: court failed to make an individualized particularized finding justifying restraints; shackling infringed rights and impeded counsel communication.	State: court exercised discretion to restrain; bench trial reduced risk of juror prejudice; no record showing communication impairment.	Held: Court erred by not making a particularized finding, but error was harmless beyond a reasonable doubt in bench trial; adjudication affirmed.

State v. Hathman, 65 Ohio St.3d 403 (Ohio 1992) (inventory searches require standardized procedures and opening containers needs an articulated policy)
State v. Moore, 90 Ohio St.3d 47 (Ohio 2000) (automobile exception permits warrantless vehicle searches when probable cause exists)
Wyoming v. Houghton, 526 U.S. 295 (1999) (probable cause to search a vehicle extends to containers belonging to passengers)
Ornelas v. United States, 517 U.S. 690 (1996) (probable cause is based on objective facts and totality of circumstances)
Arizona v. Gant, 556 U.S. 332 (2009) (limits on searches incident to arrest but distinguishable from automobile-exception searches)
Deck v. Missouri, 544 U.S. 622 (2005) (shackling a defendant in front of a jury implicates presumption of innocence and requires justification)
Maryland v. Dyson, 527 U.S. 465 (1999) (no special exigency required to search a vehicle immediately when probable cause exists)