State v. Evans, 2014 Ohio 4703

Dayton police officer stopped Evans after he rolled through a stop sign and the vehicle’s plates did not match the car’s registration.
During the stop Evans made furtive movements, could not produce his license, and appeared nervous; officer ordered him out of the car.
On the driver’s seat the officer saw a glass pipe with residue (plain view) and recovered ~5 grams of marijuana from Evans’ pocket.
The officer searched the center console and found an unlabeled pill bottle containing 21 pills; pills were later identified as oxycodone.
Evans was indicted for aggravated possession of drugs; he moved to suppress the oxycodone and his pre-Miranda statement denying a prescription.
Trial court suppressed the statement but denied suppression of the pills; Evans pled no contest, was convicted, and appealed the denial as to the seized oxycodone.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless search of the vehicle was lawful under the automobile exception	The State: officer had probable cause (pipe + marijuana) and vehicle was readily mobile, so automobile exception justified search	Evans: no exception applied; search violated Fourth Amendment and evidence must be suppressed	Court: upheld search under automobile exception — probable cause existed after plain-view pipe and recovered marijuana; mobility satisfied exigency requirement
Whether the plain-view observation justified further search	The State: pipe was lawfully observed after valid stop and Evans’ exit, making incriminating nature immediately apparent	Evans: discovery/inference insufficient to justify searching closed containers in console without a warrant	Court: plain-view observation of pipe + recovery of marijuana gave probable cause to search vehicle, including console where pills were found

Terry v. Ohio, 392 U.S. 1 (1968) (stop-and-frisk principles and Fourth Amendment limits on seizures)
Coolidge v. New Hampshire, 403 U.S. 443 (1971) (elements of the plain-view doctrine)
State v. Williams, 55 Ohio St.2d 82 (1978) (Ohio adoption of plain-view requirements)
Chambers v. Maroney, 399 U.S. 42 (1970) (automobile exception to warrant requirement)
California v. Carney, 471 U.S. 386 (1985) (vehicle mobility as exigency for searches)
Pennsylvania v. Labron, 518 U.S. 938 (1996) (probable cause + vehicle mobility permits warrantless search)
Maryland v. Dyson, 527 U.S. 465 (1999) (no separate exigency beyond vehicle mobility required)
State v. Mills, 62 Ohio St.3d 357 (1992) (Ohio discussion of automobile exception)
Xenia v. Wallace, 37 Ohio St.3d 216 (1988) (warrantless searches are per se unreasonable; State bears burden to justify exception)