vehicle under the automobile exception (Ohio) · Go Syfert
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vehicle under the automobile exception in Ohio

6 Ohio opinions name it 2 courts 2016–2026 3 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 (7)

CaseFollowedCited
State v. Graygreen
ohioctapp · 2025 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026State v. Gray, 2025-Ohio-4607, ¶ 1-2 (1st Dist.).

11
State v. Robinsongreen
ohioctapp · 2016 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024See State v. Robinson, 2016-Ohio-905 (4th Dist.) ¶ 26, citing State v. Chaffins, 2014-Ohio-1969, ¶ 18 (4th Dist.), and State v. Williams, 2013-Ohio-594, ¶ 25 (4th Dist.).

11
State v. Chaffinsgreen
ohioctapp · 2014 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024See State v. Robinson, 2016-Ohio-905 (4th Dist.) ¶ 26, citing State v. Chaffins, 2014-Ohio-1969, ¶ 18 (4th Dist.), and State v. Williams, 2013-Ohio-594, ¶ 25 (4th Dist.).

11
State v. Williamsgreen
ohioctapp · 2013 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024See State v. Robinson, 2016-Ohio-905 (4th Dist.) ¶ 26, citing State v. Chaffins, 2014-Ohio-1969, ¶ 18 (4th Dist.), and State v. Williams, 2013-Ohio-594, ¶ 25 (4th Dist.).

11
State v. Evansgreen
ohioctapp · 2014 · cited in 1 Ohio opinions naming this issue, 2020–2020
1 sentence

2020Montgomery No. 25866, 2014-Ohio-4703, ¶ 19 (after observing the pipe in plain view and recovering marijuana from the defendant’s front pocket, the officer had sufficient probable cause to believe that the vehicle may contain additional contraband, thus justifying a search of the vehicle under the automobile exception to the warrant requirement); see also Pounds, 2d Dist.

11
Carroll v. United Statesgreen
scotus · 1925 · cited in 1 Ohio opinions naming this issue, 2018–2018
2 sentences

2018See Carroll v. United States , 267 U.S. 132 , 155-156, 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless search of an automobile is not unreasonable under the Fourth Amendment when officers have probable cause to believe the vehicle contains contraband).

2018See Carroll v. United States , 267 U.S. 132 , 155-156, 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless search of an automobile is not unreasonable under the Fourth Amendment when officers have probable cause to believe the vehicle contains contraband).

11
State v. Perkinsgreen
ohio · 1985 · cited in 1 Ohio opinions naming this issue, 2018–2018
1 sentence

2018Perkins at 196, 480 N.E.2d 763 . {¶ 28} The state argues that the local police officer's observation of a capsule on the vehicle's floorboard provided probable cause to believe that the vehicle contained contraband and, thus, to conduct a warrantless search of the vehicle under the automobile exception to the warrant requirement.

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 (3)

CaseCitedYears
State v. Duch green
ohioctapp · 2025
1 sentence

2025In other words, it has yet to be determined whether Moore and Vega remain good law. {¶49} Some guidance can be found in Duch, 2025-Ohio-1162 (5th Dist.), where the court considered whether the smell of marijuana, observed after a traffic stop, supported an officer asking the driver of the vehicle to perform field-sobriety 17 OHIO FIRST DISTRICT COURT OF APPEALS tests.

12025–2025
State v. Pounds, Unpublished Decision (6-16-2006) neutral
ohioctapp · 2006
1 sentence

2020Montgomery No. 21257, 2006-Ohio-3040 (a police officer's observation of marijuana on the passenger floor gave him probable cause to believe that the defendant's vehicle -9- contained other contraband; thus, the police officer was entitled to search the vehicle pursuant to the automobile exception to the warrant requirement).

12020–2020
State v. Moore green
ohio · 2000
1 sentence

2016As the Ohio Supreme Court stated, "if the smell of marijuana, as detected by a person who is qualified to recognize the odor, is the sole circumstance, this is sufficient to establish probable cause" to search a vehicle under the automobile exception "based exclusively upon the odor of marijuana coming from the defendant's vehicle." Moore, 90 Ohio St.3d at 50-51 .

12016–2016

Where else courts name it

CA 16 (2009–2026) NY 8 (2011–2022) NE 7 (1990–2024) OH 6 (2016–2026) IL 5 (2022–2026) LA 4 (1994–2024) IN 4 (2018–2025) MN 4 (1998–2025) MA 3 (2014–2015) MI 3 (2015–2025) ND 3 (2009–2026) AZ 2 (2020–2026) VA 2 (2022–2024) PA 2 (2015–2024) IA 2 (2022–2022) TX 2 (1996–2019) KS 2 (2003–2009)

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.

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