State v. Waters, 2025 Ohio 4479

Waters was stopped after officers observed him pull away from a curb without signaling and suspected license-plate obstruction.
Officers smelled marijuana from the vehicle and Waters admitted recent marijuana use while behind the wheel.
A search of Waters’s car revealed a locked bag containing a firearm, pills, and fentanyl.
Waters moved to suppress the evidence on Fourth Amendment grounds; the trial court denied the motion.
On appeal, the court affirmed, holding probable cause existed to stop and to search the vehicle.
Ohio precedent cited includes Moore and Wright regarding marijuana odor and probable cause, under conditions prior to recreational legalization.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by probable cause or reasonable suspicion	Waters lacked basis for stop; no signal or license-plate issue documented.	Officers had probable cause based on observed traffic violation and obscured plate.	Stop supported by probable cause.
Whether the vehicle search was justified by probable cause	Odor alone did not establish probable cause post-legal changes; Moore is not controlling.	Odor plus Waters’s admission and DUI statute provided probable cause to search.	Search justified by probable cause; no Fourth Amendment violation.

State v. Brown, 2020-Ohio-896 (1st Dist. 2020) (stop reasonable when probable cause or reasonable suspicion exists)
State v. Slaughter, 2018-Ohio-105 (1st Dist. 2018) (minor traffic violations can justify stops under totality of circumstances)
State v. Batchili, 2007-Ohio-2204 (1st Dist. 2007) (trial court credibility findings respected on suppression review)
State v. Moore, 90 Ohio St.3d 47 (Ohio Supreme Court 2000) (odor of marijuana can establish probable cause to search)
State v. Wright, 2024-Ohio-1763 (1st Dist. 2024) (pre-legalization context; dog alert plus odor supports probable cause)