State v. Windle
2017 Ohio 7813
| Ohio Ct. App. | 2017Background
- On July 30, 2013 officers responded to a Go Mart after the shift manager reported a person slumped in a parked car; the manager asked police to check welfare and to have the person leave.
- Officers approached, awakened Timothy Windle, observed signs of impairment (sweating, dilated pupils, disorientation), and Windle fumbled in the console when roused.
- Officers ordered Windle out; he produced a stash can with a hypodermic needle; he was arrested for possession of drug abuse instruments and placed in a patrol car.
- Officers then searched the vehicle and found a baseball bat, Coleman fuel, tubing, and methamphetamine residue; items used in meth manufacture led to felony indictments and forfeiture specifications.
- Windle moved to suppress; the trial court denied the motion. He pleaded no contest and was sentenced to three years. The Fourth District affirmed denial of suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was initial officer contact lawful? | Police: consensual encounter/well‑being check justified approach | Windle: officers lacked lawful reason to initiate contact | Held: Approach to rouse occupant was a lawful consensual encounter (not a seizure) |
| Did community‑caretaker/emergency‑aid exception justify entry/detention? | State: well‑being check supports officer actions | Windle: no emergency, so caretaking exception doesn’t apply | Held: Caretaker exception did not apply (no immediate need), but initial contact remained lawful as consensual |
| Was continued detention (ordering out, brief detention) lawful? (Terry analysis) | State: officers developed reasonable, articulable suspicion from appearance/behavior | Windle: detention became an unlawful fishing expedition after no medical emergency found | Held: Detention justified—totality (disoriented, dilated pupils, sweating, bulge in clothing, slumped with wipers/radio on) gave reasonable suspicion |
| Was the warrantless vehicle search lawful? (automobile exception) | State: probable cause existed to search for contraband/evidence | Windle: search unconstitutional; officers lacked probable cause/relied on inventory or arrest‑search labels | Held: Probable cause existed (open view bat, drug paraphernalia, needle, signs of drug use); automobile exception justified warrantless search |
Key Cases Cited
- Burnside v. Ohio, 100 Ohio St.3d 152 (2003) (standard of appellate review for suppression rulings)
- Roberts v. Ohio, 110 Ohio St.3d 71 (2006) (trial court as factfinder on suppression hearings)
- Belton v. Ohio, 149 Ohio St.3d 165 (2016) (appellate standards on factual findings in suppression review)
- California v. Acevedo, 500 U.S. 565 (1991) (automobile exception and limits on warrant requirement)
- Terry v. Ohio, 392 U.S. 1 (1968) (investigatory stop/Terry‑stop reasonable suspicion standard)
- Whren v. United States, 517 U.S. 806 (1996) (officer subjective intent irrelevant to Fourth Amendment analysis)
- Cady v. Dombrowski, 413 U.S. 433 (1973) (community‑caretaking function and warrant exception)
- United States v. Arvizu, 534 U.S. 266 (2002) (totality‑of‑circumstances, deference to officers’ training in reasonable‑suspicion analysis)
- Illinois v. Gates, 462 U.S. 213 (1983) (probable cause as a ‘fair probability’ standard)