State v. Parker, 2012 Ohio 839

Parker was convicted by a jury of assembly or possession of chemicals used to manufacture methamphetamine; she was sentenced to two years and up to three years of post-release control.
Officers stopped Parker and Rike in December 2009 after a suspected shoplifting incident, impounded the car, and searched it leading to Parker’s arrest.
Parker moved to suppress the vehicle search and her subsequent statements; the suppression motion was denied.
Trial occurred in November 2010 with testimony from officers, a detective, a chemist, and Rike; Parker claimed the materials belonged to him.
Parker appeals on suppression grounds, sufficiency of the evidence, and manifest weight of the evidence.
The court ultimately upheld the conviction, affirming the trial court’s rulings on the key issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the vehicle search was valid under Fourth Amendment standards	Parker contends the search was unlawful	State argues automobile exception and inventory search justified the seizure	Search not justified by exigent circumstances; inventory search valid; evidence admissible
Whether there was sufficient evidence to sustain the conviction	Parker argues insufficiency of proof	State contends evidence supports each element	Sufficient evidence supported the conviction; Crim.R.29 was properly denied
Whether the conviction is against the manifest weight of the evidence	Weight arguments challenge credibility and inferences	State contends verdict reasonable from the evidence	Conviction not against the manifest weight; reasonable juror could have credited the State's theory

State v. Mills, 62 Ohio St.3d 357 (Ohio 1992) (automobile exception to warrant requirement; exigent circumstances)
Chambers v. Maroney, 399 U.S. 42 (U.S. 1970) (vehicle search without warrant under exigent circumstances)
Michigan v. Long, 463 U.S. 1032 (U.S. 1983) (protective search of vehicle for weapons during stop)
Colorado v. Bertine, 479 U.S. 367 (U.S. 1987) (inventory searches of impounded vehicles are permissible)
State v. Mesa, 87 Ohio St.3d 105 (Ohio 1999) (inventory searches must follow standard procedures)
State v. Cole, 93 Ohio App.3d 712 (Ohio 1994) (valid inventory search requires standard practice not pretext)
South Dakota v. Opperman, 428 U.S. 364 (U.S. 1976) (legitimate basis for vehicle inventory searches)
Rakas v. Illinois, 439 U.S. 128 (U.S. 1978) (standing to challenge searches; passenger lacking interest)
Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (limits on vehicle search incident to arrest)
Wilcox, 177 Ohio App.3d 609 (Ohio 2008) (protective search for weapons; time factors undermine justification)
State v. Curry, 95 Ohio App.3d 93 (Ohio 1994) (standards for reviewing suppression rulings)
State v. Broaddus, 2010-Ohio-490 (Ohio 2010) (suppression/standard of review)