State v. Celaya, 2019 Ohio 2747

Background

At ~1:30 a.m., Officer Quigney saw Anthony Celaya carrying a large plastic-wrapped item between alleys and then digging through a trash can; two police cruisers pulled into the alley and officers approached.
Quigney asked whether Celaya had knives; Celaya said he had a couple and indicated they were in his right front pants pocket, then said “go ahead” when asked to retrieve them.
Quigney reached into Celaya’s right front pocket, manipulated items, then searched Celaya’s right jacket pocket, removed items, returned them, and later again removed a small clear Tupperware-like container (containing methamphetamine).
The officer handcuffed Celaya shortly after removing the container and later found syringes in his backpack; Celaya was charged with meth possession and paraphernalia.
At the suppression hearing the trial court found (1) the encounter was not consensual, (2) officers lacked reasonable articulable suspicion, and (3) the search exceeded the scope of consent; the court suppressed the drug evidence.
On appeal the court held the initial encounter was lawful (reasonable suspicion existed), but the officer exceeded the scope of Celaya’s consent when the container was removed from the pocket, so suppression was affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the initial encounter a consensual encounter or an unlawful detention?	Encounter was consensual or, at minimum, officers had reasonable articulable suspicion to detain.	Encounter was not consensual; Celaya was effectively blocked and not free to leave.	Court assumed possible Terry stop but held officers had reasonable suspicion (so encounter lawful).
Did officers have reasonable, articulable suspicion to justify a stop?	Yes — late-night, residential alley, carrying large wrapped item, digging in trash consistent with theft/receipt of stolen property.	No — defense argued lack of articulable facts to detain.	Held: totality of circumstances gave reasonable suspicion; stop lawful.
Was the search based on consent limited to retrieval of knives, or did it exceed scope?	Search was within scope: Celaya told officer knives were present and gave consent to retrieve them; officer could check multiple locations and remove items to search pocket.	Consent was limited to right front pants pocket for knives; officer went into jacket and later removed container beyond consent.	Held: officer exceeded the scope of consent when he removed the container (search beyond consent); suppression proper.
Could plain-view or other exception save the seizure of the container?	(State) If container was lawfully in the pocket during a permitted search or plainly incriminating, seizure would be lawful.	(Defendant) No reliance because container was obtained outside the scope of consent.	Majority did not reach plain-view; dissent argued plain-view might apply and would remand for consideration.

Key Cases Cited

Terry v. Ohio, 392 U.S. 1 (establishes investigatory stop standard for reasonable articulable suspicion)
Florida v. Bostick, 501 U.S. 429 (consensual encounter factors; whether reasonable person feels free to leave)
United States v. Mendenhall, 446 U.S. 544 (test for seizure: reasonable person would believe not free to leave)
Florida v. Jimeno, 500 U.S. 248 (scope of consent measured by objective reasonableness)
Schneckloth v. Bustamonte, 412 U.S. 218 (voluntariness of consent under totality of circumstances)
Coolidge v. New Hampshire, 403 U.S. 443 (limits and application of the plain-view doctrine)
Horton v. California, 496 U.S. 128 (conditions for plain-view seizure)
State v. Robinette, 80 Ohio St.3d 234 (Ohio: consent can validate search but voluntariness required when detention precedes consent)