State v. Taylor, 2019 Ohio 2018

Confidential informant arranged and completed a controlled buy of heroin from Guy Taylor; police observed the transaction and confirmed the drug.
Within days police obtained a search warrant for Taylor's residence and executed it under the department's "swoop" policy: they waited for Taylor to leave the house, drive two blocks, then stopped his vehicle.
During the traffic stop officers told Taylor they had a warrant for his home; Taylor admitted he had heroin on his person and officers searched him, seizing the drug.
Taylor was indicted for trafficking and possession of heroin and moved to suppress the heroin seized from his person, arguing the search warrant for his residence did not authorize the vehicle stop or his arrest.
The trial court granted the suppression: it held Bailey limited detentions under a search warrant to the immediate vicinity, found no reasonable suspicion for the stop, and ruled the swoop policy unconstitutional; it also required exigent circumstances for a warrantless arrest.
The State appealed; the appellate court reviewed the suppression hearing testimony (only the officer testified) and reversed, holding probable cause existed from the controlled buy and that exigent circumstances were not required for a public, warrantless arrest based on probable cause.

Issue	State's Argument	Taylor's Argument	Held
Whether officers needed an arrest warrant or exigent circumstances to arrest Taylor in public after a prior controlled buy	Warrantless public arrest lawful where officers had probable cause from the controlled buy; no exigency needed	Police should have obtained an arrest warrant; absence of exigent circumstances makes the arrest/search unlawful	Reversed trial court: probable cause existed and exigency is not required for public arrest based on probable cause
Whether the traffic stop and detention were supported by reasonable suspicion or were effectively an arrest	Stop was justified by probable cause derived from the controlled buy	Stop was only a detention to facilitate the house search and not supported by suspicion	Court treated the stop as an arrest supported by probable cause and therefore lawful
Whether evidence seized from Taylor should be excluded as remedy for Fourth Amendment violation	Suppression unnecessary because arrest/search lawful	Exclusion was proper because swoop policy and warrantless arrest/search violated the Fourth Amendment	Suppression reversed as court found no constitutional violation requiring exclusion

Bailey v. United States, 568 U.S. 186 (2013) (limits on detaining a person incident to execution of a search warrant at the premises)
Terry v. Ohio, 392 U.S. 1 (1968) (reasonable suspicion standard for brief investigative stops)
United States v. Watson, 423 U.S. 411 (1976) (warrantless public arrests valid when supported by probable cause; exigency not constitutionally required)
State v. Brown, 115 Ohio St.3d 55 (2007) (Ohio follows Watson: public arrest without warrant is lawful when probable cause exists)
State v. Heston, 29 Ohio St.2d 152 (1972) (older Ohio decision discussing practicability of obtaining a warrant for felony arrests)