State v. Mendonca, 2023 Ohio 1780

Mendonca was stopped for speeding; officer found his out-of-state license suspended and the rental's registration and insurance expired. Officer ordered the vehicle to be towed per Fayetteville policy.
Officer Waddle conducted an inventory search of the impounded rental: a small baggie of cocaine was found between the front seats and a sealed, >2-pound brick of cocaine was found hidden behind a trunk access panel.
Mendonca was arrested; a subsequent search of the patrol cruiser where he sat revealed methamphetamine.
Mendonca moved to suppress, arguing the tow/search violated the Fourth Amendment because the officer failed to follow policy, acted with a pretextual investigatory motive, and exceeded the scope of an inventory search. The trial court denied the motion.
A jury convicted Mendonca of first-degree trafficking and possession of cocaine and third-degree aggravated trafficking and possession; the court imposed an aggregate mandatory-minimum sentence.
On appeal Mendonca raised (1) suppression error (policy noncompliance, pretext, scope) and (2) sufficiency/manifest-weight challenges to the cocaine convictions; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer violated towing/release policy by not inquiring into why license was suspended	Tow valid: policy does not require inquiry; suspension + expired reg/insurance justified impound	Officer should have asked why license suspended before towing	No error; policy compliance not required and tow lawful
Whether tow/inventory was pretextual investigatory search	Inventory performed in good faith under standard practice; no evidence of ulterior motive	Tow was a pretext to search vehicle for evidence	No evidence of pretext; inventory reasonable and not unconstitutional
Whether opening trunk access panel exceeded scope of an inventory search	Policy authorizes inventory of trunk/compartments, including closed areas; scope includes hidden compartments	Searching behind access panel exceeded inventory scope and was investigatory	Search within lawful inventory scope; examining compartments (including access panels) permissible
Whether convictions for trafficking and possession were supported by sufficient evidence / against manifest weight	Circumstantial proof (admitted recent cocaine use, small bag in passenger area, photo and text referencing cocaine, large cash amount) tied Mendonca to the trunk brick	No direct evidence he knew of the >2 lb brick; convictions rest on speculation	Convictions supported by sufficient circumstantial evidence and not against manifest weight

State v. Turner, 163 Ohio St.3d 421 (2020) (standard for mixed question of law and fact on suppression review)
State v. Burnside, 100 Ohio St.3d 152 (2003) (trial court as factfinder on suppression; appellate review of facts for clear error)
State v. Robinson, 58 Ohio St.2d 478 (1979) (inventory searches reasonable when in good faith and pursuant to standard police practice)
State v. Heinish, 50 Ohio St.3d 231 (1990) (circumstantial evidence may support conviction)
State v. Jenks, 61 Ohio St.3d 259 (1991) (sufficiency standard: review evidence in light most favorable to prosecution)
United States v. Lumpkin, 159 F.3d 983 (6th Cir. 1998) (inventory searches may include engine and other compartments)
United States v. Torres, 828 F.3d 1113 (9th Cir. 2016) (upholding inventory search of non-obvious compartments such as air-filter box)