State v. Boyd, 2020 Ohio 125

Officers on foot surveillance at Gina’s Party Store, a high‑crime area; Detective Reeb observed unusual loitering in the parking lot.
Reeb saw Boyd (wearing a reflective vest) near a parked Chevy Impala; another officer provided a photo and a plate check showed Boyd regularly drove the Impala and had an outstanding arrest warrant.
Reeb followed Boyd into the store, asked him outside, handcuffed and Mirandized him, and found car keys in Boyd’s pocket; Boyd said the Impala was his and suspected he was being stopped for driving without a license.
Before towing the Impala, Reeb observed a baggie of what appeared to be cocaine in plain view in a coin holder on the driver’s door; police seized it and Boyd later admitted (post‑Miranda) the cocaine was his.
Boyd moved to suppress the seized evidence and statements; the trial court denied the motion. Boyd pled no contest, was sentenced to community control, and appealed the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether seizure of cocaine violated Fourth Amendment (plain‑view/automobile exception)	Police were lawfully on premises, saw contraband in plain view, and had probable cause to seize and search the vehicle	Seizure/search invalid because Boyd was not observed driving and was not shown to be recent occupant	Held: Plain‑view observation of contraband in vehicle gave probable cause; seizure/search lawful under automobile exception
Whether towing/inventory of vehicle was justified	Vehicle parked in a public business lot in a high‑crime area; securing vehicle to prevent vandalism/theft justified tow/inventory	Towing improper because vehicle was legally parked and there was no public‑safety need; thus inventory search invalid	Held: Tow was reasonable under circumstances; regardless, contraband was observed in plain view before tow, so search was lawful
Admissibility of Boyd’s post‑arrest statements	Statements followed Miranda warning and were voluntary	Statements should be excluded if resulting from unlawful detention/search	Held: Miranda warnings were given before admissions; statements admissible

Minnesota v. Dickerson, 508 U.S. 366 (1993) (discusses limitations on warrantless searches and exceptions)
Coolidge v. New Hampshire, 403 U.S. 443 (1971) (articulates plain‑view doctrine)
Thompson v. Louisiana, 469 U.S. 17 (1984) (on limits of warrantless searches)
Wong Sun v. United States, 371 U.S. 471 (1963) (fruit‑of‑the‑poisonous‑tree and exclusionary principles)
Pennsylvania v. Labron, 518 U.S. 938 (1996) (automobile exception when car is readily mobile)
Maryland v. Dyson, 527 U.S. 465 (1999) (no separate exigency beyond vehicle mobility for automobile exception)
California v. Carney, 471 U.S. 386 (1985) (vehicle mobility and reduced expectation of privacy)
United States v. Ross, 456 U.S. 798 (1982) (scope of vehicle search under automobile exception)
State v. Moore, 90 Ohio St.3d 47 (2000) (Ohio discussion of automobile exception and probable cause)
State v. Mills, 62 Ohio St.3d 357 (1992) (vehicle mobility as traditional exigency)