State v. White, 2020 Ohio 5544

Police observed a vehicle do a "burnout" and make a right turn without signaling; officer stopped the vehicle.
Officer asked White for license; White said he had none; dispatch revealed White’s license was suspended and the passenger had an outstanding arrest warrant.
Because neither occupant could lawfully drive away, officers decided to impound/tow under Dayton Police tow policy; an inventory search was performed.
Inventory uncovered keys under the driver’s seat and a locked glove compartment; officers used the keys to open it and found a clear bag of crystalline methamphetamine (lab: 111.49 g).
White was charged with aggravated possession (second-degree felony), moved to suppress, lost a suppression hearing, waived a jury, was convicted after a bench trial, and sentenced to a mandatory 3-year term (consecutive to another sentence).
On appeal (Anders review), counsel and the court considered suppression, sufficiency/manifest-weight, jury-waiver validity, and sentencing; the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion to suppress: validity of stop, tow, and inventory search	Stop supported by observed traffic violations; tow/inventory authorized by department policy; search was inventory, not pretextual	Stop was improper because vehicle was legally parked; tow was pretext to search after refusal to consent	Denial of suppression affirmed: stop valid, impound/inventory complied with policy and not pretextual
Sufficiency of evidence for aggravated possession	Officers’ observations (White reaching toward glove box), keys found under driver’s seat, and lab results support constructive possession and knowledge	No direct proof White owned the car or actually possessed the drugs; alternative explanations plausible	Conviction upheld: evidence sufficient; not against manifest weight
Manifest-weight challenge	N/A (State relies on witness credibility and physical evidence)	Trial court lost its way by crediting officers over defendant	Rejected: trier of fact entitled to weigh credibility; no miscarriage of justice
Jury waiver validity	Waiver was written, signed, filed, made part of record, and made in open court after court explained difference	(Raised initially by pro se) waiver possibly defective because transcript missing previously	Waiver valid: strict R.C. 2945.05 requirements met; waiver knowing and voluntary

Terry v. Ohio, 392 U.S. 1 (1968) (reasonable-suspicion standard for stops)
Florida v. Jimeno, 500 U.S. 248 (1991) (Fourth Amendment reasonableness inquiry)
South Dakota v. Opperman, 428 U.S. 364 (1976) (inventory-search exception to warrant requirement)
City of Blue Ash v. Kavanagh, 113 Ohio St.3d 67 (2007) (application of impound/inventory procedures)
State v. Retherford, 93 Ohio App.3d 586 (2d Dist. 1994) (trial court as factfinder on suppression)
State v. Lomax, 114 Ohio St.3d 350 (2007) (statutory requirements for written jury-waiver)
State v. Jackson, 141 Ohio St.3d 171 (2014) (presumption that written jury waiver is voluntary and knowing)
Anders v. California, 386 U.S. 738 (1967) (procedures for appointed counsel to withdraw when appeal is frivolous)
Penson v. Ohio, 488 U.S. 75 (1988) (appellate court’s duty in Anders review)