State v. Shrewsbury, 2014 Ohio 716

Agents Germany and Shannon, plainclothes, observed Shrewsbury at a gas station and suspected possible open-container violation.
Germany saw Shrewsbury exchange something hand-to-hand with someone in a pickup; Shannon did not observe the exchange due to parking.
Shrewsbury drank from a metallic can; agents believed it looked like beer/alcoholic beverage based on experience.
Agents determined to approach the parked car to determine whether the can contained alcohol, identifying themselves as officers.
Shrewsbury reached toward the floor when approached; agents ordered him to place hands on the steering wheel for safety.
A clear plastic container with pills was revealed; later, a search uncovered additional Suboxone; Shrewsbury was arrested and convicted of possession.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop/search violated the Fourth Amendment.	Shrewsbury contends there was no reasonable suspicion for a warrantless seizure.	Agents acted to ensure safety after a furtive movement and suspected open-container violation.	The seizure was reasonable; suppression denied.

Emerson v. State, 134 Ohio St.3d 191 (2012-Ohio-5047) (establishes Fourth Amendment standards and suppression framework)
Burnside v. Smith, 100 Ohio St.3d 152 (2003-Ohio-5372) (deference to trial court on suppression findings; independent legal review)
Katz v. United States, 389 U.S. 347 (1967) (open view vs. plain view; reasonable expectation of privacy concept)
Florida v. Royer, 460 U.S. 491 (1983) (types of police-citizen encounters and seizure thresholds)
United States v. Mendenhall, 446 U.S. 544 (1980) (clarifies criteria for consensual encounters and seizures)
United States v. Williams, 525 F. App’x 330 (2013) (framework for investigatory stops and safety-based seizures)