State v. Taylor
2013 Ohio 814
Ohio Ct. App.2013Background
- Defendant Nathan Taylor convicted of possession of crack cocaine (1–5 grams).
- Motion to suppress challenged the pat-down as unreasonable under Fourth Amendment and Ohio Constitution.
- Officer House pat-searched Taylor during a traffic stop after stopping a Camaro linked to drug activity.
- Informant tip described two men in a distinctive Camaro; Taylor matched the description.
- Pat-down yielded crack cocaine; Taylor admitted narcotics after Miranda warnings.
- Trial court overruled suppression motion; Taylor pled no contest and was sentenced to community control.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reasonable grounds for pat-down | Taylor lacked individualized suspicion | House had no reason to believe armed and dangerous | Pat-down justified; reasonable suspicion existed |
| Scope of pat-down | Search exceeded permissible boundaries | Pat-down was an unlawful intrusiveness | Pat-down did not exceed permissible scope; could be defense to arrest incident |
Key Cases Cited
- State v. Roberts, 2d Dist. Montgomery No. 23219, 2010-Ohio-300 (2010-Ohio-300) (reasonable suspicion and Terry stop standards for pat-downs)
- State v. Shipp, 2d Dist. Montgomery No. 24933, 2012-Ohio-6189 (2012-Ohio-6189) (scope of pat-down and necessity of individualized suspicion; arrest-incident exception discussed)
- State v. Allen, 2d Dist. Montgomery No. 22663, 2009-Ohio-1280 (2009-Ohio-1280) (buttocks-area pat-down discussed; intrusiveness considerations)
- State v. Gillis, 2d Dist. Montgomery No. 21868, 2007-Ohio-3456 (2007-Ohio-3456) (weighs gun/weapon discovery during pat-down and safety concerns)
- State v. McBeath, 2d Dist. Montgomery No. 23929, 2010-Ohio-3653 (2010-Ohio-3653) (pat-down scope limited to exterior; aligns with weapon-search prohibitions)