State v. Gardner, 135 Ohio St. 3d 99

Officer observed outside-county pickup, tracked car to a residence in a high-crime area.
Car registered to Easter, who had an outstanding arrest warrant for a drug case.
Gardner and another male were seen exiting the residence and entering Easter's car.
Officer arrested Easter and observed Gardner reaching toward the car interior; Gardner was then handcuffed.
Gardner was searched and crack cocaine was found prior to Miranda; warrant later identified as for a traffic violation.
Trial court denied suppression, citing the warrant as an automatic cleansing factor; appellate court remanded for proper factual findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an outstanding arrest warrant eliminates Fourth Amendment privacy protections	Gardner lacks privacy due to warrant	Warrant purports to justify seizure; no privacy interest	No; privacy rights remain and suppression required to be evaluated on totality of circumstances
Whether suppression was appropriate given patdown and seizure context	Warrant discovery should purge illegality	Stop/search justified by warrant context	Remand for findings on reasonable suspicion and plain-view/feel evidence viability
Whether discovery of warrant after seizure affects legality of initial stop	Post hoc discovery cannot validate illegality	Lawful seizure independent of warrant disclosure timing	Remand to assess if initial seizure was reasonable under totality of circumstances

Payton v. New York, 445 U.S. 573 (1980) (arrests in home require warrants; privacy interests preserved)
Ker v. California, 374 U.S. 23 (1963) (privacy protected; fundamental rights central to warrants/entry)
Terry v. Ohio, 392 U.S. 1 (1968) (reasonable suspicion standard for brief detentions)
Delaware v. Prouse, 440 U.S. 648 (1979) (probable cause required for vehicle stops; balance of intrusion and purpose)
Bell v. Wolfish, 441 U.S. 520 (1979) (balancing test for government intrusions on individual rights)