Law Enforcement Bulletin

Sign up for newsletters and other news
Media > Newsletters > Law Enforcement Bulletin > September 2015 > State v. Taylor 2015 Ohio 3252

Law Enforcement Bulletin RSS feeds

State v. Taylor 2015 Ohio 3252

Question: Can officers continue to search a vehicle after discovering the contraband that prompted the search?

Quick Answer: Yes. As long as probable cause exists to believe additional contraband may be concealed in the area to be searched.
Facts: Officers conducted a traffic stop for excessive window tint and failure to signal a turn. As they approached the car, both officers noticed a strong odor of marijuana coming from the vehicle. Having probable cause based on the odor, officers searched the car. During the search, officers located two marijuana cigarettes and a magazine of live ammunition. Officers also found a set of keys that opened the glove box where they recovered an unloaded handgun. The defendant argued that police exceeded the scope of the search of his car without probable cause when they continued to search after finding marijuana cigarettes (the source of the smell prompting the search). The court concluded the smell of marijuana provided the officers with probable cause to search the passenger compartment of the suspect’s car and the probable cause does not end once some drugs are found. 

Keep in Mind: When probable cause exists to search a vehicle, officers are permitted to search anywhere the item of contraband may be located, including the glove box and other closed containers.