State v. Patterson, 2021 Ohio 4617

Sgt. Ropos observed Patterson driving a Pontiac with no visible rear registration late at night; Patterson said a temporary tag was in the upper-left rear windshield.
Dispatch confirmed Patterson was the registered owner but had a suspended driving status; Patterson produced an Ohio ID (no valid license) and was the sole occupant.
Under LCSO policy, Ropos summoned a tow because the vehicle could not be lawfully driven and conducted an on‑scene inventory search before the vehicle was towed.
During the inventory, Ropos found drugs in a plastic bag in the driver’s door; Patterson was indicted for aggravated possession (felony) and related counts/specifications.
Patterson moved to suppress the evidence and later pled no contest to aggravated possession, reserving the right to challenge his sentence under the Reagan Tokes Act; the trial court denied suppression and imposed an indefinite sentence of 3 to 4.5 years.
On appeal the court affirmed: the inventory search was lawful and Patterson’s constitutional challenges to the Reagan Tokes Act were not ripe for review.

Issue	State's Argument	Patterson's Argument	Held
Lawfulness of impound/tow	Tow was permitted under LCSO policy for driving with suspended status and a vehicle stopped on a traveled roadway	Refused a timely chance to have a third party retrieve the car, so tow (and inventory) was unnecessary/unlawful	Tow was lawful; no bad faith or pretext; failure to allow pickup did not make impoundment unconstitutional
Validity of inventory search	Search was a routine, administrative inventory incident to a lawful impoundment	Search was a warrantless evidentiary/protective search requiring suspicion and was therefore unreasonable	Inventory search is an administrative caretaking exception and not governed by protective‑search rules; search was reasonable
Requirement to use less intrusive alternatives	Police need not adopt alternative procedures if their standard policy is reasonable and applied in good faith	Officer could have delayed towing to allow another driver; less intrusive means existed	Fourth Amendment does not demand the least intrusive means; reasonable, good‑faith policy suffices
Constitutional challenges to Reagan Tokes Act	Challenges premature on appeal because it is uncertain whether DRC will extend incarceration beyond the minimum term	Reagan Tokes is void for vagueness, violates separation of powers, jury right, and due process — claims ripe now	Challenges are not ripe for review on direct appeal; court declines to decide constitutionality

Katz v. United States, 389 U.S. 347 (establishes warrant requirement for searches and seizures)
Schneckloth v. Bustamonte, 412 U.S. 218 (warrant requirement subject to established exceptions)
Colorado v. Bertine, 479 U.S. 367 (upholds inventory search exception when pursuant to standard police practice)
South Dakota v. Opperman, 428 U.S. 364 (community‑caretaking doctrine; impoundment and inventory justified for public safety)
Illinois v. Lafayette, 462 U.S. 640 (reasonableness of administrative search procedures not judged by whether less intrusive alternatives existed)
Blue Ash v. Kavanagh, 113 Ohio St.3d 67 (Ohio precedent: routine inventory of lawfully impounded vehicle is reasonable if not pretextual)
State v. Hathman, 65 Ohio St.3d 403 (inventory searches are administrative and do not require probable cause)
State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression rulings)
State v. Leak, 145 Ohio St.3d 165 (discusses community‑caretaking functions and impoundment)