State v. Guthrie

2025 Ohio 5458
CourtOhio Court of Appeals
DecidedDecember 8, 2025
DocketCA2024-11-023
StatusPublished

This text of 2025 Ohio 5458 (State v. Guthrie) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Guthrie, 2025 Ohio 5458 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Guthrie, 2025-Ohio-5458.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

MADISON COUNTY

STATE OF OHIO, : CASE NO. CA2024-11-023 Appellee, : OPINION AND vs. : JUDGMENT ENTRY 12/8/2025 MICHAEL W. GUTHRIE, :

Appellant. :

:

CRIMINAL APPEAL FROM MADISON COUNTY COURT OF COMMON PLEAS Case No. CRI20240062

Nicholas A. Adkins, Madison County Prosecuting Attorney, and Michael S. Klamo, Assistant Prosecuting Attorney, for appellee.

Shannon M. Treynor, for appellant.

____________ OPINION

SIEBERT, J.

{¶ 1} Michael Guthrie appeals his conviction for aggravated possession of a drug

and possession of a fentanyl-related compound. He argues the trial court erred in denying Madison CA2024-11-023

his motion to suppress and finding the "automobile exception" applied to law

enforcement's search of Guthrie's vehicle. We disagree and conclude the automobile

exception did apply. Evidence of illegal drug use within plain sight in the vehicle as well

as an ajar interior panel gave law enforcement probable cause to believe that more

evidence could be found within the vehicle's steering column. We affirm the trial court's

denial of the motion to suppress.

Background

{¶ 2} The underlying facts of this case are not contested. Around midnight on

March 9, 2024, Sergeant Kyle Kauffman conducted a traffic stop on Guthrie because the

license plate on his vehicle (a Mercedes) was registered to a different car (a Ford). Police

determined Guthrie operated the vehicle under an administrative license suspension and

impounded the vehicle. There were no other occupants in the car.

{¶ 3} Officer Bailey Hickman responded to the scene to conduct an inventory

search following the vehicle's impoundment at the scene. Officer Hickman testified at

Guthrie's suppression hearing that during the search he observed an open pack of Narcan

in the driver side door and several yellow pills—later identified to be Gabapentin—on the

floor next to the driver's seat. Officer Hickman found no prescription bottle for the pills in

the car. On the driver side floorboard, Officer Hickman observed a burnt, cut straw with a

black and brown residue. Another officer at the scene found foil with a burnt residue inside

the center console. Officer Hickman testified that in his experience, straws and foil are

frequently used together to smoke illicit drugs.

{¶ 4} After discovering these items, Officer Hickman noticed a slightly out of place

plastic panel under the steering wheel. He testified that previous criminal interdiction

courses taught officers that out of place panels are a potential sign of tampering. Officer

Hickman used his flashlight to look inside the panel and observed the corner of a plastic

-2- Madison CA2024-11-023

bag containing a white substance inside the paneling. After opening the panel, Officer

Hickman recovered the bag. The bag contained methamphetamine and a small capsule

of fentanyl.

{¶ 5} Guthrie argued at the suppression hearing that Officer Hickman's search

inside the steering wheel panel exceeded the constitutional scope of an inventory search.

The trial court, however, denied the motion to suppress, finding the discovery of the burnt

straws and foil as well as loose prescription pills gave the officers probable cause to

conduct a full automobile search without a warrant. Guthrie subsequently pled no contest

to charges of aggravated possession of a drug and possession of a fentanyl-related

compound, and the trial court sentenced Guthrie to an indefinite term of three to four and

a half years in prison.

{¶ 6} Guthrie now appeals.

Standard of Review and Applicable Law

{¶ 7} "Appellate review of a ruling on a motion to suppress presents a mixed

question of law and fact." State v. Gray, 2012-Ohio-4769, ¶ 15 (12th Dist.). Recognizing

that trial courts are in the "best position to weigh the evidence in order to resolve factual

questions and evaluate witness credibility," appellate courts must accept the factual

findings of the trial court "if they are supported by competent, credible evidence." State v.

Hensgen, 2017-Ohio-8793, ¶ 16 (12th Dist.). If the factual findings are supported, "the

appellate court must then independently determine, without deference to the conclusion

of the trial court, whether the facts satisfy the applicable legal standard." State v.

Burnside, 2003-Ohio-5372, ¶ 8.

{¶ 8} Both Section 14, Article I, of the Ohio Constitution and the Fourth

Amendment to the United States Constitution prohibit the government from conducting

"unreasonable" searches and seizures of people, their houses, and their possessions

-3- Madison CA2024-11-023

without a warrant. The requirement for the police to obtain a warrant to conduct a search

"is the rule, not the exception." State v. Burroughs, 2022-Ohio-2146, ¶ 13. The warrant

requirement ensures that a "neutral and detached magistrate" determines the lawfulness

of the search warrant request instead of "the officer engaged in the often competitive

enterprise of ferreting out crime." Id., quoting Johnson v. United States, 333 U.S. 10, 14

(1948). A search without a warrant is only reasonable if it falls "within a specific exception

to the warrant requirement." Id., quoting Riley v. California, 573 U.S. 373, 382 (2014).

{¶ 9} One such exception to the constitutional protection against warrantless

searches is an "inventory search" wherein police may search a lawfully impounded

vehicle without a warrant in order document the vehicle's contents. State v. Resnick,

2007-Ohio-3717, ¶ 12 (12th Dist.). Such searches "protect[] the police against claims or

disputes over lost or stolen property . . . [as well as] from potential danger." Id.

{¶ 10} Another exception, relevant here, is the "automobile exception, which

allows warrantless searches of an automobile by police officers who have probable cause

to believe that the vehicle contains contraband." State v. Gray, 2023-Ohio-338, ¶ 19 (12th

Dist.). This court defines "probable cause" in terms of the automobile exception as "a

belief reasonably arising out of circumstances known to the seizing officer, that an

automobile or other vehicle contains that which by law is subject to seizure and

destruction." State v. Popp, 2011-Ohio-791, ¶ 27 (12th Dist.). Probable cause is a "fact-

dependent" determination and "turns on what the officers knew at the time they conducted

the search." State v. Raphael, 2015-Ohio-3179, ¶ 23 (12th Dist.). Once established,

probable cause "justifies a search of every part of the vehicle and its contents that may

conceal the object of the search." State v. Howard, 2008-Ohio-2706, ¶ 11 (1st Dist.).

Analysis

{¶ 11} Guthrie acknowledges that law enforcement could lawfully conduct an

-4- Madison CA2024-11-023

inventory search of the vehicle after detaining him. He argues, however, that the loose

pills, Narcan, burnt foil, and burnt straws were all legal or untested items that could not

give probable cause to search the steering column of the vehicle.

{¶ 12} We disagree. Upon beginning a permissible inventory search of Guthrie's

vehicle, officers quickly identified in plain view several indicators of illegal drug activity:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Johnson v. United States
333 U.S. 10 (Supreme Court, 1948)
State v. Raphael
2015 Ohio 3179 (Ohio Court of Appeals, 2015)
State v. Howard, C-070174 (6-6-2008)
2008 Ohio 2706 (Ohio Court of Appeals, 2008)
State v. Resnick, Ca2006-05-118 (7-23-2007)
2007 Ohio 3717 (Ohio Court of Appeals, 2007)
State v. Hensgen
2017 Ohio 8793 (Ohio Court of Appeals, 2017)
State v. Taylor
2020 Ohio 5079 (Ohio Court of Appeals, 2020)
State v. Burroughs
2022 Ohio 2146 (Ohio Supreme Court, 2022)
State v. Gray
2023 Ohio 338 (Ohio Court of Appeals, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 5458, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-guthrie-ohioctapp-2025.