State v. Moody, 2020 Ohio 3899

At ~2:00 a.m. officers found Jeremy Moody stopped at a green light with brake lights on; he appeared unconscious in the driver’s seat and a small black plastic bag rested on his lap.
Officer Evans tapped the window; Moody awoke, put the car in park, opened the door, grabbed the bag, and told officers he had smoked marijuana. Evans took the bag after ordering him to release it.
Officers discovered Moody lacked a valid driver’s license and decided to have the vehicle towed under Dayton Police Department policy.
During a pre-tow inventory, officers located marijuana, money, a digital scale, and the black bag, which Evans testified he recognized as containing methamphetamine after handling it; Evans also testified he smelled a strong odor of marijuana.
Moody moved to suppress the drug evidence as the product of an unlawful search; the trial court denied suppression, Moody pled no contest to aggravated possession, was convicted, and appealed solely challenging the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of search under inventory-exception	Inventory was lawful because vehicle was lawfully towed under city tow policy and inventory followed department procedure	Search was unlawful; evidence seized without proper warrant or probable cause	Court: Inventory-exception applies; tow and inventory were lawful and done in good faith — suppression denied
Lawfulness of officers' initial approach/investigation	Officers reasonably investigated a stopped car (impeding traffic) and acted under community-caretaker function	Moody did not contest the initial approach but argued subsequent seizure was unreasonable	Court: Officers had reasonable basis to investigate and community-caretaker justification supported the encounter
Seizure of bag when officer grabbed it before tow policy applied	Evans grabbed bag for officer safety and later recognized meth by touch; inventory would have revealed it anyway	Evans lacked specific suspicion the bag contained a weapon or contraband when he grabbed it	Court: Credited officer’s testimony; handling did not render the inventory invalid and did not violate Fourth Amendment
Probable cause based on odor of marijuana	Smell of marijuana supported search of vehicle/contents	Moody contested lack of probable cause for search/seizure	Court: Noted that odor alone would support a search (citing Moore) but ultimately upheld seizure under inventory doctrine

South Dakota v. Opperman, 428 U.S. 364 (inventory searches of impounded vehicles are an exception to the warrant requirement)
Florida v. Jimeno, 500 U.S. 248 (Fourth Amendment reasonableness standard)
Arizona v. Gant, 556 U.S. 332 (limits on warrantless vehicle searches)
Katz v. United States, 389 U.S. 347 (Fourth Amendment privacy principle)
State v. Mesa, 87 Ohio St.3d 105 (Ohio law recognizing inventory-search exception when done in good faith)
State v. Burnside, 100 Ohio St.3d 152 (appellate standard of review for suppression motions)
State v. Moore, 90 Ohio St.3d 47 (odor of marijuana can support search of vehicle)