State v. Wilson, 2018 Ohio 2377

Wilson was arrested after police found a marijuana cigarette, a digital scale, and a bag of marijuana in his parked car; he was indicted for trafficking and possession.
Officer Fusselman smelled burned marijuana on Wilson, who told officers a joint was in his car; a partner observed a marijuana cigarette in the center console.
Wilson unlocked his vehicle for officers; the officers recovered the cigarette, scale, and bag of marijuana. A subsequent pat-down earlier had found cash on Wilson, and a third party later turned over about $2,700 that Wilson allegedly gave him.
Wilson moved to suppress all evidence; the trial court granted suppression, finding an illegal 15-minute detention after an initially valid Terry stop and concluding the vehicle search and seizure of money were tainted.
The state appealed; the court of appeals reviewed the trial court’s factual findings for clear error and its legal conclusions de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the post-contact detention illegal, tainting evidence?	State: No — Wilson left and then voluntarily returned; no unlawful extended detention occurred.	Wilson: He was detained ~15 minutes after a frisk, making subsequent evidence tainted.	Court: Trial court’s finding of a 15-minute illegal detention was clearly erroneous.
Was the warrantless search of the vehicle unlawful?	State: No — officer had probable cause after observing marijuana in plain view; automobile exception applied.	Wilson: Locked car and lack of explicit consent required a warrant.	Court: Warrantless search was lawful under automobile and plain-view exceptions; consent unnecessary.
Was the seizure of the cash from the third party fruit of an illegal stop/interrogation?	State: No — officer obtained the money via an independent source (third-party statement), so exclusionary rule inapplicable.	Wilson: Money flowed from his statements while allegedly detained and pre-Miranda, so should be suppressed.	Court: Money admissible because officers had an independent source for discovery.
Were plain-view requirements satisfied for seizing contraband visible in the car?	State: Yes — officers lawfully arrived, discovery was inadvertent, incriminating nature immediately apparent.	Wilson: Discovery and subsequent search were unlawful due to alleged illegal detention.	Court: Plain-view exception satisfied; discovery lawful.

Katz v. United States, 389 U.S. 347 (establishes warrant requirement for searches absent a recognized exception)
United States v. Ross, 456 U.S. 798 (automobile exception permits warrantless search when officers have probable cause to believe vehicle contains contraband)
State v. Burnside, 100 Ohio St.3d 152 (standard of review for appellate review of suppression rulings)
State v. Carter, 69 Ohio St.3d 57 (exclusionary rule inapplicable where police have an independent source for evidence)