State v. Samuels, 2011 Ohio 2567

Samuels was indicted for possession of crack cocaine (less than one gram), a felony of the fifth degree, and charged in Franklin County since 2007.
He moved to suppress the evidence seized during a stop and search following a police surveillance of a high-crime area tied to drug activity.
Officer Orick observed Samuels exit and re-enter a doorway connected to suspected drug activity, with the time inside the apartment estimated at two to three minutes.
Orick stopped Samuels for the short duration inside the residence and then conducted a stop-and-search after detecting Samuels’ hand movements toward the vehicle console.
Crack cocaine was recovered from Samuels’ clenched hand and additional pieces from a pocket after a pat-down and cruiser transfer; field tests confirmed cocaine.
Samuels waived his Miranda rights after being read warnings; he provided statements about the drugs, which were admitted at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop/search was properly justified by an independent warrant-based authority.	Samuels	Samuels	Retroactive warrant-based authority upheld; search valid.

State v. Purser, 2007-Ohio-190 (Greene App. No. 2006 CA 14) (appellate deference to trial court on suppression and evidence review)
State v. Lynch, No official reporter cited (Montgomery App. No. 17028) (generalized hunch stop invalidated; capias not controlling)
State v. Harding, 2009 Ohio 59 (Montgomery App. No. 22747) (outstanding warrant provides independent authority for stop)
State v. Williams, 2008 Ohio 6030 (Montgomery App. No. 22535) (outstanding warrant relevance to stop/search)
State v. Jamison, 2001 Ohio App. LEXIS (Montgomery App. No. 18453) (exclusionary rule not applied to Terry stop with warrant issue)
State v. Walker-Stokes, 2008-Ohio-6552 (Montgomery App. No.) (overruled Jamison on warrant-based Terry stops)