State v. Greene, 2013 Ohio 4516

Greene was stopped for a traffic violation: no front license plate and abrupt lane change without signaling.
Greene was the sole occupant; officer observed nervous behavior during the stop.
K-9 unit was requested; during the stop, officers performed pawing/searches including a pat-down and sock search, yielding a key.
Glove box contained a pistol; the glove box was locked; officers proceeded to search under the automobile exception after the canine alert.
Greene was advised of rights later; statements at the scene and at jail were challenged; suppression motion was heard and a suppression ruling issued.
Trial court ultimately denied suppression on key aspects, but remanded for proper community-service notice regarding court costs; otherwise affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the suppression proper given detention duration and vehicle search after K-9 alert?	Greene	Greene	Denied; search upheld due to proper duration and K-9 alert.
Was the glove-box search valid after the K-9 alert and the derived key?	Greene	Greene	Upheld; glove box search permissible under automobile exception.
Were Greene's statements at the scene and jail admissible given custodial circumstances?	Greene	Greene	Evidence at the scene suppressed; jail interview properly advised and admitted.
May the court impose court costs with potential community service for failure to pay, and was proper notice given?	State	Greene	Remanded for proper community-service notification; otherwise affirmed.

State v. Parson, 2013-Ohio-2763 (2d Dist. Montgomery No. 25399 (2013)) ( Terry stop framework; duration of stop must be diligent)
State v. Ramos, 2003-Ohio-6535 (Montgomery App. (2003)) (canine sniff during traffic stop does not extend stop if done promptly)
State v. Troutman, 2012-Ohio-407 (2d Dist. Marion No. 9-11-17 (2012)) (wait for canine while delaying ticketing can nullify diligence of investigation)