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87 Ohio St. 3d 105

State v. Mesa

Ohio Supreme Court

Decided October 20, 1999

Ohio Supreme Court · decided 1999-10-20

Key passage — most relied on by later courts

“require[d] that open compartments of the vehicle are to be searched!,]’ and that locked compartments shall not be opened,’ ” and concluding that “[b]y its very terms, this language does not prohibit officers from searching closed compartments!,]” but only prohibits opening those ''that are locked”). 8 . Notably, the Matthews court distinguished our decision in Salmon, emphasizing — as we have above — that there,”

quoted by 1 later decision, including United States v. Mundy

Relies on 65 Ohio St. 3d 403 - State v. Hathman

Good law ✅— No negative treatment on recordhow we know

Decided 1999-10-20

How this case has been cited

Cited by 115 later decisions — most recently October 2025 · most notably 152 Ohio St. 3d 368 - State v. Banks-Harvey (2018), State v. Grubb (2010)

2 federal appellate · 113 state decisions

4401999200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Pfeifer, J.,

¶1dissenting. The trial court correctly granted the defendant’s motion to suppress evidence of the concealed weapon. The Lakewood Police Department’s written inventory policy sets forth that “open compartments of the *113vehicle are to be searched.” The console the gun was found in was closed. The Lakewood policy does not address closed but unlocked compartments. That being the case, the policy does not meet the requirements of State v. Hathman (1992), 65 Ohio St.3d 403, 604 N.E.2d 743. I accordingly dissent.

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