State v. Ward, 2017 Ohio 8141

December 20, 2015: Officer observed Ward’s car parked in a neighborhood known for drug trafficking; a person was leaning into the car and walked away as the officer approached.
Officer initiated a traffic stop a few seconds later after Ward pulled away from the curb without signaling.
Officer learned Ward had a suspended license and an outstanding extraditable Kentucky warrant (nonsupport); Ward was arrested on the warrant.
Officer searched Ward’s vehicle after securing him in the patrol car, relying on the automobile-exception and the officer’s belief drugs might be present; the search revealed a loaded 9mm in the center console.
Ward moved to suppress; trial court denied the motion (mistakenly finding an observed money exchange). Ward pleaded no contest, was sentenced to community control, and appealed the suppression ruling.
The appellate court reviewed de novo whether the facts known to the officer at the time of the search supplied probable cause for the automobile exception and reversed, remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had probable cause to conduct a warrantless search of Ward’s car under the automobile exception	Officer relied on totality: high-crime area, person leaning into car, person walking away, vehicle behavior — these facts supported a reasonable belief contraband would be found	Ward argued the observed facts were ambiguous/neutral, no observed hand-to-hand transaction or smell, and the officer lacked probable cause to search	Court held no probable cause: the facts known to the officer were ambiguous and insufficient to establish a fair probability that contraband would be in the vehicle; search invalid; suppression ruling should have been granted

State v. Bacher, 170 Ohio App.3d 457 (1st Dist. 2007) (warrantless searches are presumptively unreasonable; Terry reasonable-suspicion standard discussed)
Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable-suspicion standard for investigatory stops)
Brinegar v. United States, 338 U.S. 160 (1949) (probable cause defined as facts that would lead a person of reasonable caution to believe an offense is occurring)
Carroll v. United States, 267 U.S. 132 (1925) (automobile exception to the warrant requirement explained)
State v. Bobo, 37 Ohio St.3d 177 (1988) (officer may rely on reputation of area for criminal activity when determining whether an investigative stop is warranted)
State v. Carter, 69 Ohio St.3d 57 (1994) (presence in high-crime area alone is insufficient to justify an investigative stop)
State v. Williams, 55 Ohio St.2d 82 (1978) (evidence found in an illegal search does not validate the search)