immediately apparent requirement (Ohio) · Go Syfert
← Ohio issues

immediately apparent requirement in Ohio

7 Ohio opinions name it 2 courts 1986–2018 0 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

CaseFollowedCited
State v. Halczyszakgreen
ohio · 1986 · cited in 3 Ohio opinions naming this issue, 1994–2014
2 sentences

2001This requirement is met when "police have probable cause to associate an object with criminal activity," State v. Halczyszak (1986), 25 Ohio St.3d 301 , paragraph three of the syllabus. "[S]uch probable cause to associate an object with criminal activity as is obvious and evident to an ordinary police officer sufficiently satisfies the immediately apparent requirement" of the plain view doctrine.

1994This requirement is met when “police have probable cause to associate an object with criminal activity,” State v. Halczyszak (1986), 25 Ohio St.3d 301 , 25 OBR 360, 496 N.E.2d 925 , paragraph three of the syllabus, which probable cause “may arise from the character of the property itself.” Id. at 304-305 , 25 OBR at 363, 496 N.E.2d at 931 . “[S]uch probable cause to associate an object with criminal activity as is obvious and evident to an ordinary police officer sufficiently satisfies the immediately apparent requirement” of the plain view doctrine.

13
Texas v. Browngreen
scotus · 1983 · cited in 1 Ohio opinions naming this issue, 1986–1986
2 sentences

1986It was asserted below that reliance on Texas v. Brown, supra, is unwarranted because it is a plurality opinion.

1986See the concurring opinion of Justices Powell and Blackmun, id. at 746 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Horton v. California green
scotus · 1990
2 sentences

2018"The [evidence], therefore, must be seized pursuant to a warrant or the seizure must be under circumstances that excuse the failure to get the warrant." State v. Kesler , 111 Ohio App.3d 98 , 100, 675 N.E.2d 875 (3d Dist.1996), citing Horton , 496 U.S. at 138 , 110 S.Ct. 2301 , 110 L.Ed.2d 112 .

2018"The [evidence], therefore, must be seized pursuant to a warrant or the seizure must be under circumstances that excuse the failure to get the warrant." State v. Kesler , 111 Ohio App.3d 98 , 100, 675 N.E.2d 875 (3d Dist.1996), citing Horton , 496 U.S. at 138 , 110 S.Ct. 2301 , 110 L.Ed.2d 112 .

12018–2018
State v. Kesler green
ohioctapp · 1996
2 sentences

2018"The [evidence], therefore, must be seized pursuant to a warrant or the seizure must be under circumstances that excuse the failure to get the warrant." State v. Kesler , 111 Ohio App.3d 98 , 100, 675 N.E.2d 875 (3d Dist.1996), citing Horton , 496 U.S. at 138 , 110 S.Ct. 2301 , 110 L.Ed.2d 112 .

2018"The [evidence], therefore, must be seized pursuant to a warrant or the seizure must be under circumstances that excuse the failure to get the warrant." State v. Kesler , 111 Ohio App.3d 98 , 100, 675 N.E.2d 875 (3d Dist.1996), citing Horton , 496 U.S. at 138 , 110 S.Ct. 2301 , 110 L.Ed.2d 112 .

12018–2018
Minnesota v. Dickerson green
scotus · 1993
2 sentences

2004No. 96-A-0063, 1997 Ohio App. LEXIS 2817 , relying on Minnesota v. Dickerson (1993) 508 U.S. 366 , we stated: {¶ 16} "* * * the Supreme Court analogized the `plain view' doctrine to those cases in which contraband is `plainly felt' and its identity as contraband is `immediately apparent' in a valid Terry stop situation. `The `immediately apparent' requirement of the `plain view' doctrine is satisfied when police have probable cause to associate an object with criminal activity.' Thus, by analogy, the probable cause standard applies to the immediately apparent requirement in the `plain feel' co

2004Probable cause exists when `there is a fair probability that contraband or evidence of a crime will be found in a particular place.' {¶ 17} In Dickerson , the officer conducting the pat-down search realized that the item was contraband `only after `squeezing, sliding and otherwise manipulating the contents of the defendant's pocket' * * *.' Therefore, the Supreme Court concluded that the officer's `continued exploration' of the suspect's pocket was not authorized under Terry . " (Internal citations omitted.) Id. at 10-11 . {¶ 18} In the instant case, both Ladner and Weber testified it was comm

12004–2004
State v. Waddy red
ohio · 1992
1 sentence

2002Id. {¶ 24} We have already determined that the initial investigatory stop of appellant's vehicle was a lawful intrusion.

12002–2002
Gary Leland Cotton v. United States green
ca9 · 1967
1 sentence

1986Cotton v. United States (C.A.9, 1967), 371 F. 2d 385, 392 ; United States v. Graham (C.A.6, 1968), 391 F. 2d 439, 443 , certiorari denied (1968), 393 U.S. 941 ; United States v. Johnson (C.A.5, 1970), 431 F. 2d 441 .

11986–1986
United States v. Robert Graham, United States of America v. Grady Lee Tucker green
ca6 · 1968
1 sentence

1986Cotton v. United States (C.A.9, 1967), 371 F. 2d 385, 392 ; United States v. Graham (C.A.6, 1968), 391 F. 2d 439, 443 , certiorari denied (1968), 393 U.S. 941 ; United States v. Johnson (C.A.5, 1970), 431 F. 2d 441 .

11986–1986
United States v. James Leland Johnson green
ca5 · 1970
1 sentence

1986Cotton v. United States (C.A.9, 1967), 371 F. 2d 385, 392 ; United States v. Graham (C.A.6, 1968), 391 F. 2d 439, 443 , certiorari denied (1968), 393 U.S. 941 ; United States v. Johnson (C.A.5, 1970), 431 F. 2d 441 .

11986–1986
Howard v. California green
scotus · 1968
1 sentence

1986Cotton v. United States (C.A.9, 1967), 371 F. 2d 385, 392 ; United States v. Graham (C.A.6, 1968), 391 F. 2d 439, 443 , certiorari denied (1968), 393 U.S. 941 ; United States v. Johnson (C.A.5, 1970), 431 F. 2d 441 .

11986–1986

Where else courts name it

PA 26 (2000–2025) OH 7 (1986–2018) CT 5 (2000–2018) IA 2 (2022–2022) NH 2 (2001–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check