Background - In May 2016 Devon R. Edwards was charged with drug offenses following a police encounter at a parking lot; an anonymous 911 caller reported a black Chevy Blazer with a temporary tag and at least one male in a white T‑shirt selling drugs. - Officer Ester arrived in uniform in a marked cruiser, pulled behind the described vehicle without lights/siren, exited, and approached the vehicle; he observed occupants matching the tip and smelled marijuana emanating from the vehicle. - Two men standing outside had outstanding warrants and were handcuffed; Edwards (front‑seat passenger) briefly exited, was ordered back in, then was later ordered out and searched; officers recovered cash from Edwards and drug paraphernalia and controlled substances from inside and beneath the car. - Officers’ testimony and a body‑camera recording were presented at a joint suppression hearing; the trial court granted Edwards’s motion to suppress, reasoning the anonymous tip was uncorroborated and insufficient to justify the stop/search. - The state appealed, arguing the encounter was initially consensual and that officers obtained reasonable suspicion/probable cause independent of the anonymous tip (notably from the smell of marijuana), justifying the detention and warrantless vehicle search. - The appellate court reversed: it held the initial approach was a consensual encounter that yielded probable cause once officers smelled marijuana and received confirmation from the driver that occupants had been smoking nearby, so suppression was improper. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---|---| | Whether the officers’ initial contact with vehicle occupants was an unconstitutional stop based solely on an anonymous tip | The encounter was consensual and, even if it ripened into an investigative detention, officers had reasonable suspicion and probable cause based on articulable facts (odor of marijuana, occupants’ behavior) | The seizure and search stemmed from an insufficient anonymous tip that lacked inside information and corroboration, so evidence must be suppressed | The court held the initial approach was a consensual encounter; once officers smelled marijuana and received corroboration from the driver, they had probable cause to search the vehicle and detain occupants; suppression wrongly granted | ### Key Cases Cited Florida v. J.L., 529 U.S. 266 (2000) (an anonymous tip lacking predictive information or basis of informant's knowledge cannot alone justify a stop) Florida v. Bostick, 501 U.S. 429 (1991) (police approach that does not restrain a person can be a consensual encounter not triggering Fourth Amendment seizure analysis) State v. Moore, 90 Ohio St.3d 47 (2000) (officer’s detection of marijuana odor alone can establish probable cause to search a vehicle) State v. Jordan, 104 Ohio St.3d 21 (2004) (partial corroboration of an anonymous tip does not necessarily supply reasonable suspicion of criminal activity)