State v. Hunter, 2012 Ohio 2302

Hunter was arrested Oct 15, 2010; charged with PCP possession and possessing criminal tools with $300 forfeiture.
Officers investigated a dispatch about a man selling drugs at 10206 Way Ave and canvassed nearby blocks.
They encountered two men at East 104th St & Way Ave; defendant appeared confused and did not respond to questions.
An odor of PCP was detected as officers approached; defendant admitted PCP use.
During a frisk, officers found a small PCP vial; cap broken and odor emitted from the vial.
The trial court denied suppression on May 2, 2011; Hunter pled no contest on May 11, 2011 and was sentenced to two years of community control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop supported by reasonable suspicion to constitute a Terry stop?	State contends facts showed reasonable suspicion.	Hunter contends no reasonable suspicion warranted the stop.	Stop supported; reasonable suspicion found.
Was the pat-down/search for weapons permissible and did plain-feel apply?	State argues pat-down proper; PCP odor justified further seizure.	Hunter argues excessive search and unlawful seizure.	Pat-down limited to weapons; plain-feel seizure of PCP permissible.
Did the custodial stop exceed Terry limits given immediate contraband apparent?	State maintains community-caretaking justified encounter.	Hunter asserts overreach beyond brief Terry stop.	Encounter validated under community-caretaking and immediate plain-feel seizure.

United States v. Mendenhall, 446 U.S. 544 (1980) (consensual encounters may become seizures under coercive factors)
Terry v. Ohio, 392 U.S. 1 (1968) (establishes permissible brief search of outer clothing for weapons)
Minnesota v. Dickerson, 508 U.S. 366 (1993) (plain-feel exception to seize immediately apparent contraband)
State v. Dunn, 131 Ohio St.3d 325 (2012) (community-caretaking/emergency-aid exception validates stop for safety/aid)