State v. Vargas

2025 Ohio 4482
CourtOhio Court of Appeals
DecidedSeptember 26, 2025
Docket2025-CA-1
StatusPublished

This text of 2025 Ohio 4482 (State v. Vargas) 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. Vargas, 2025 Ohio 4482 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Vargas, 2025-Ohio-4482.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT GREENE COUNTY

STATE OF OHIO : : C.A. No. 2025-CA-1 Appellee : : Trial Court Case No. 2023 CR 0601 v. : : (Criminal Appeal from Common Pleas FERNANDO J. VARGAS : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on September 26, 2025, the judgment

of the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

ROBERT G. HANSEMAN, JUDGE

TUCKER, J., and HUFFMAN, J., concur. -2- OPINION GREENE C.A. No. 2025-CA-1

ADRIAN KING, Attorney for Appellant MEGAN A. HAMMOND, Attorney for Appellee

HANSEMAN, J.

{¶ 1} Defendant-Appellant Fernando Vargas appeals from his conviction for

aggravated possession of drugs. According to Vargas, the trial court’s evaluation of whether

a police officer’s cruiser impeded his path of travel on foot, purportedly resulting in his

detention, was clearly erroneous, and the court should have granted his motion to suppress

evidence.

{¶ 2} Based on the record before the trial court, Vargas’s initial encounter with a

police officer was consensual. The officer saw drugs in plain view, which provided probable

cause for Vargas’s seizure and arrest. The trial court did not err in overruling the motion to

suppress. Therefore, the judgment of the trial court is affirmed.

I. Facts and Course of Proceedings

{¶ 3} On November 13, 2023, Vargas was indicted with one count of aggravated

possession of drugs (methamphetamine), a second-degree felony, with a specification for

forfeiture of the drugs and contraband. Vargas filed a motion to suppress evidence. The trial

court held a hearing on the motion and received testimony from one witness, Detective

Connor Mulcahy.

{¶ 4} At the time of the hearing, Mulcahy had been employed as police officer for a

little more than six years; all his employment, other than one month, had been with the city

of Fairborn. Mulcahy’s normal duties at the time of the alleged crime were to patrol roads,

investigate traffic and criminal offenses, respond to calls, and protect neighborhoods. -3- Mulcahy had conducted approximately one hundred drug investigations during his

employment. Based on Mulcahy’s training and experience, he was familiar with how illegal

drugs are packaged and concealed.

{¶ 5} On June 19, 2023, Mulcahy was on duty, working the day shift as a patrol officer.

He was in a marked police cruiser, wearing his uniform. He was equipped with a functional

cruiser camera and body camera. The cameras recorded Mulcahy’s interaction with Vargas.

The trial court received copies of the cruiser and body camera recordings, a photo of Vargas

at the scene, and Vargas’s bag of illegal drugs as the State’s exhibits. During the patrol,

Mulcahy saw Vargas, whom Mulcahy knew from prior on-duty interactions. Mulcahy had

previously received information from community members suggesting that Vargas was

selling drugs. A neighbor had flagged Mulcahy down, and the police had pictures and videos

of Vargas allegedly selling drugs. Mulcahy was aware that most of the people Vargas

associated with, such as friends and a girlfriend, had been arrested due to drug usage or

were known to be around drugs. Mulcahy also had previously arrested people on Vargas’s

front porch for warrants when Vargas was inside the home.

{¶ 6} Around 2:00 to 3:00 p.m. that day, Mulcahy noticed Vargas walking in the Wright

View neighborhood. The neighborhood had higher police activity than most other places in

Fairborn, with reported crime including weapon complaints, thefts, domestic crimes, and

many drug complaints. When Mulcahy saw Vargas, he had intended to “check in” with

Vargas because he knew Vargas’s partner had recently given birth, and he wanted to see

how Vargas was doing. Vargas had not committed any crimes while he was walking.

Mulcahy turned around but saw that Vargas was gone. However, Mulcahy saw a car leaving

from the area where he had seen Vargas and began following it. Mulcahy wanted to see -4- how Vargas’s baby was, but he also knew Vargas did not have a driver’s license. If Vargas

had been driving, he would not have been legally permitted to do so.

{¶ 7} Mulcahy followed the car for a couple of minutes, just down the street, and did

not see any traffic violations. The car proceeded into the driveway of an apartment complex

and pulled into a parking space situated along the driveway. The space was one of several

parking spaces marked diagonally along both sides of the driveway. Mulcahy stopped his

cruiser behind the car in the middle of the driveway, not in a parking spot. The driver’s side

of Mulcahy’s cruiser faced the rear of the car. Vargas got out of the passenger side of the

car and began walking toward the cruiser. At that time, Mulcahy was still sitting in his cruiser

with his arm up on the window. When Vargas walked up, he was free to leave, and when

Mulcahy addressed Vargas, he used a conversational tone.

{¶ 8} Mulcahy had just intended to see how Vargas was doing, but he noticed

something hanging out of Vargas’s waistline that was immediately apparent to him as

contraband based on his training and experience. The object was a plastic bag tied in a knot,

a common practice of people who purchase or possess drugs, and was in the center of

Vargas’s waistband. The bag was clear but had a whitish tint as if it contained residue, which

was consistent with Mulcahy’s experience with packaged narcotics. In all the drug

investigations in which Mulcahy had participated, he had never seen a similar baggie that

did not contain drugs. As Vargas approached the cruiser, he drew his hands, which were

holding items, close to his waist as if he was trying to hide what Mulcahy had already seen.

{¶ 9} Mulcahy got out of his cruiser, called dispatch to let them know where he was,

and placed Vargas in handcuffs because he had probable cause to believe a crime was

occurring. Mulcahy walked Vargas to the other side of his cruiser to separate him from the

driver so that he could administer Miranda rights and talk to Vargas separately. Before -5- Mulcahy walked Vargas over to the other side of the cruiser, he grabbed the bag by the

knots and pulled it out of the front of the waistband.

{¶ 10} The trial court found the encounter in the parking lot was consensual and that

the drugs fell within the plain-view exception to the warrant requirement. Accordingly, the

court overruled the motion to suppress. Vargas subsequently pled no contest to the second-

degree felony charge and the forfeiture specification. The trial court imposed an indefinite

sentence of two to three years in prison but stayed the sentence pending appeal. Vargas’s

timely appeal followed.

II. Ruling on the Motion to Suppress

{¶ 11} Vargas’s assignment of error asserts that the trial court’s factual findings

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2025 Ohio 4482, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-vargas-ohioctapp-2025.