State v. Jenkins, 2016 Ohio 5190

On May 1, 2013 Sgt. Neil Laughlin followed and stopped a vehicle after observing it change lanes without signaling. Terrell Jenkins was the front passenger; a woman drove and a man sat in back.
Laughlin approached on the passenger side, smelled a strong odor of marijuana from the open front passenger window, and radioed for backup.
Occupants were removed and questioned separately; inconsistent statements about destination increased officers’ suspicions.
After additional officers arrived, they searched the vehicle and found cocaine under the front passenger seat.
Jenkins was indicted for drug trafficking, possession, and drug paraphernalia; he moved to suppress the stop, search, and any statements. The trial court denied the motion; Jenkins pleaded no contest and was sentenced to three years. He appealed the suppression denial.

Issue	Jenkins' Argument	State's Argument	Held
Legality of the initial traffic stop	Stop lacked reasonable, articulable suspicion; officer testimony not credible	Officer observed lane change without signal, authorizing stop under traffic law	Court upheld stop: officer had reasonable, articulable suspicion to stop for a traffic violation
Extension of the stop / vehicle search	Officer impermissibly prolonged the stop to search for drugs; no marijuana found	Officer smelled a strong, recent marijuana odor, providing additional suspicion to continue detention and investigate	Court held smell of marijuana gave additional articulable facts to justify continued detention and investigation
Suppression of post-stop statements (Miranda)	Statements were taken without Miranda warnings and should be suppressed	No specific challenged statements identified; defendant failed to show prejudice	Court rejected the Miranda claim for lack of identified statements or demonstrated prejudice
Exclusion of evidence as fruits of unconstitutional search	All evidence should be excluded due to Fourth Amendment violations	No constitutional violation occurred; evidence admissible	Court affirmed denial of suppression and admission of evidence

Florida v. Royer, 460 U.S. 491 (1983) (not all seizures require probable cause; investigatory detentions are permitted)
Terry v. Ohio, 392 U.S. 1 (1968) (officer must have specific, articulable facts supporting reasonable suspicion for a stop)
Carroll v. United States, 267 U.S. 132 (1925) (Fourth Amendment facts judged by an objective standard)
State v. Burnside, 100 Ohio St.3d 152 (2003) (appellate review accepts trial court factual findings if supported and then applies de novo review to legal conclusion)
State v. Mays, 119 Ohio St.3d 406 (2008) (officer may stop a vehicle upon reasonable suspicion the driver committed a traffic violation)