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State v. Booker

2026-08-28

Summary

Holding. The trial court properly denied Booker's motion to suppress because the warrantless search of the bookbag was justified under the automobile exception—officers had probable cause based on surveillance showing a gunman with a bookbag taking cover near the SUV before the bookbag disappeared, and the trial court's advisement regarding the mandatory prison sentence complied with criminal procedure rules because the charged offense carried a mandatory penalty. The judgment is affirmed.

William Booker was charged with aggravated methamphetamine trafficking and possession. Police officers conducted a warrantless search of a bookbag inside a parked SUV after surveillance footage showed a gunman with a bookbag firing a rifle and then taking cover near the vehicle before fleeing. The officers obtained probable cause to search the SUV based on these observations and the gunman's disappearance without the bookbag or rifle, which led to discovery of methamphetamine. Booker challenged the search as a Fourth Amendment violation and claimed his no-contest plea was unknowing because the trial court allegedly misstated the mandatory nature of sentencing.

The appellate court upheld the trial court's denial of Booker's motion to suppress. The search was justified under the automobile exception because officers had probable cause to believe the bags in the SUV contained evidence of the shooting based on the totality of circumstances—specifically, the gunman's appearance with a bookbag, his proximity to the SUV, and his departure without the bookbag. The court distinguished this case from similar precedents involving only neutral conduct in high-crime areas. Regarding the plea, the court confirmed that Booker did face a mandatory prison sentence because he possessed more than five times the bulk amount of methamphetamine (16.261 grams, when 15 grams triggers the requirement) within 1,000 feet of a school.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether warrantless search of bookbag in parked SUV violated Fourth Amendment automobile exception doctrine
  • Whether officers had probable cause to search based on circumstantial evidence from shooting surveillance
  • Whether trial court's plea colloquy complied with criminal procedure rules regarding advisement of mandatory sentencing

Procedural posture

Booker appealed from his conviction following his no-contest plea in Hamilton County Court of Common Pleas, challenging the trial court's denial of his motion to suppress and the validity of his plea.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as State v. Booker, 2026-Ohio-3371.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250699

TRIAL NO. B-2502393

Plaintiff-Appellee, :

vs. :

WILLIAM BOOKER, :

JUDGMENT ENTRY

Defendant-Appellant. :

This cause was heard upon the appeal, the record, and the briefs.

For the reasons set forth in the Opinion filed this date, the judgment of the trial court is affirmed.

Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs be taxed under App.R. 24.

The court further orders that (1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and (2) the mandate be sent to the trial court for execution under App.R. 27.

To the clerk:

Enter upon the journal of the court on 8/28/2026.

Pursuant to App.R. 30, the clerk is directed to send all parties, or their counsel if represented, a copy of the court’s judgment and note such action on the docket.

By:_______________________

Administrative Judge

[Cite as State v. Booker, 2026-Ohio-3371.]

IN THE COURT OF APPEALS

FIRST APPELLATE DISTRICT OF OHIO

HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-250699

TRIAL NO. B-2502393

Plaintiff-Appellee, :

vs. :

WILLIAM BOOKER, : OPINION

Defendant-Appellant. :

Criminal Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: August 28, 2026

Connie Pillich, Hamilton County Prosecuting Attorney, and Paula E. Adams, Assistant Prosecuting Attorney, for Plaintiff-Appellee,

Angela J. Glaser, for Defendant-Appellant.

[Cite as State v. Booker, 2026-Ohio-3371.]

BOCK, Judge.

{¶1} In two assignments of error, defendant-appellant William Booker

challenges his aggravated-drug-trafficking conviction. First, he maintains that law

enforcement’s warrantless search of his bookbag, which was in an SUV parked on a

public street, violated his Fourth Amendment rights. Second, he argues that the trial

court’s noncompliance with Crim.R. 11 rendered his no-contest plea involuntary and

unknowing. Unconvinced, we overrule both assignments of error.

{¶2} First, the search was justified under the automobile exception to the

warrant requirement. Officers had probable cause to search the bookbag in the SUV

because the officers were aware of surveillance footage suggesting that a gunman

discarded the bookbag while fleeing the scene of a shooting. Second, the trial court

correctly advised Booker that he faced a mandatory prison sentence and was ineligible

for community control because he admitted to having more than five times the bulk

amount of methamphetamine in the vicinity of a school zone.

{¶3} We affirm Booker’s conviction.

I. Factual and Procedural History

{¶4} The State charged Booker with aggravated trafficking of

methamphetamine in violation of R.C. 2925.03(A)(2) and aggravated possession of

methamphetamine in violation of R.C. 2925.11(A).

A. Suppression hearing

{¶5} Booker moved to suppress the methamphetamine and evidence

recovered by officers in his bookbag as a violation of his Fourth Amendment rights

and all statements he made during and after his arrest as a violation of his Fifth

Amendment rights. At the suppression hearing, Booker abandoned his Fifth

OHIO FIRST DISTRICT COURT OF APPEALS

Amendment claims and stipulated that he had the keys to, and therefore a possessory

interest in, the SUV that was searched.

{¶6} The Cincinnati Police Department deploys surveillance technology to

monitor Cincinnati’s residents and visitors. Cincinnati Police Officer Benjamin

Williamson testified that ShotSpotter detected the sound of gunshots at the

intersection of Vine Street and Green Street, and then on Republic Street, in

Cincinnati. To Williamson, the sound and speed of the gunshots suggested a firearm

larger than a handgun. Williamson called the Cincinnati Police Department’s RealTime Crime Center (“Crime Center”), which sent Williamson video footage of a

gunman with a bookbag firing a rifle “towards Vine Street.” Williamson testified that

the gunman had an accomplice, who was carrying a handgun and wearing a

“camouflage jacket.” The two fled and “ducked down behind a tan SUV that was

parked” on a public street. He described that area as Cincinnati’s “most violent . . .

open-air drug market.”

{¶7} The Crime Center told Williamson that one of the SUV’s doors opened

momentarily before the shooters disappeared down a nearby alleyway. According to

Williamson, that alleyway is “where they go and ditch narcotics, guns, anything like

that.” Officers responding to the scene found a handgun and camouflage jacket in the

alleyway, but they did not find a rifle. Williamson could not determine from the

surveillance footage whether the gunman carried the bookbag into the alleyway.

{¶8} The Crime Center drew Williamson’s attention to two men that

resembled the gunman and his accomplice standing near the SUV. In bodycam

footage, Williamson told other officers that the gunman and accomplice huddled near

the trunk of the SUV. Williamson peered into the window of the SUV and spotted “two

black bags” in the trunk and “a black bag in the front passenger seat.” At the hearing,

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OHIO FIRST DISTRICT COURT OF APPEALS

Williamson speculated the gunman had tossed his bookbag into the SUV and that the

bookbag “could have contained more firearms and . . . the rifle.” Williamson did not

suspect that Booker was the gunman or accomplice and began speaking with Booker

about the bags in the SUV. Booker said the bookbag in the front passenger

compartment was his and consented to a search before revoking that consent.

{¶9} Williamson testified that there were no canine units in the Cincinnati

Police Department capable of detecting firearms. Yet, Williamson requested “a K-9

unit to do an open-air sniff of the vehicle to determine if there was contraband for a

probable cause search.” Williamson, determined to search the vehicle, testified that he

wanted to “exhaust all [] resources” to search the SUV due to the “exigency of the

situation,” so he needed to secure the vehicle. Williamson estimated that obtaining a

warrant would have taken two to three hours.

{¶10} Officer Knapp responded with his canine partner, Bravo, to “complete a

free-air drug sniff” as part of the investigation into the missing rifle. After circling the

SUV twice, Bravo alerted Officer Knapp to the odor of narcotics near the front

passenger door. Officer Williamson testified that Bravo’s alert gave him probable

cause to search the SUV. While Williamson found a digital scale and individually

packaged methamphetamine pills in the bookbag, he never found the rifle.

{¶11} The trial court denied Booker’s motion to suppress and found the

vehicle search did not violate the Fourth Amendment because law enforcement had

probable cause to search the SUV before Bravo’s dog sniff due to exigent

circumstances. And Bravo’s alert gave officers probable cause to search the bookbag

“for anything really.”

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B. Booker pleaded no contest

{¶12} Booker withdrew his not-guilty pleas and pleaded no contest to the

charges. The trial court accepted Booker’s no-contest pleas, found him guilty, merged

the possession count into the trafficking count, and imposed a five-to-seven-and-ahalf-year sentence.

II. Analysis

{¶13} On appeal, Booker challenges the trial court’s denial of his motion to

suppress and the validity of his plea.

A. First Assignment of Error: The bag search was permissible under the

Fourth Amendment’s automobile exception

{¶14} Booker argues that the trial court erred by denying his motion to

suppress because the officers’ search of his bookbag violated his rights under the

Fourth Amendment.

{¶15} An appeal of a trial court’s decision denying or granting a motion to

suppress raises a mixed question of law and fact. See State v. Ward, 2017-Ohio-8141,

¶ 12 (1st Dist.). We accept the trial court’s finding of facts that are supported by

competent and credible evidence. Id. But we independently review the application of

those facts to the law. Id.

{¶16} The Fourth Amendment promises freedom from “unreasonable

searches and seizures.” U.S. Const., amend. IV. That freedom demands “that searches

be conducted pursuant to a warrant issued by an independent judicial officer.”

California v. Carney, 471 U.S. 386, 390 (1985). Securing a warrant is “the rule, not the

exception.” State v. Burroughs, 2022-Ohio-2146, ¶ 13. A warrantless search is “‘per se

unreasonable’” unless the State shows that an established exception to the warrant

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requirement justifies the warrantless search. See Ward at ¶ 13, quoting State v.

Bacher, 2007-Ohio-727, ¶ 8 (1st Dist.).

{¶17} The automobile exception authorizes “a warrantless search of an entire

vehicle if the officers have probable cause to believe that they will discover evidence of

a crime.” In re L.S., 2016-Ohio-5582, ¶ 15 (1st Dist.); see California v. Acevedo, 500

U.S. 565, 580 (1991) (“The police may search an automobile and the containers within

it where they have probable cause to believe contraband or evidence is contained.”).

The automobile exception is justified by the exigencies created by “the inherent

mobility of automobiles” and the “public nature of automobile travel.” South Dakota

v. Opperman, 428 U.S. 364, 367 (1976). Probable cause exists for a warrantless search

if a reasonable officer would believe, based on “‘the totality of the circumstances

known to the officer at the time of the search,’” that evidence of a crime will be found

in a specific place. Ward at ¶ 20, quoting State v. Grubbs, 2017-Ohio-41, ¶ 33 (6th

Dist.).

{¶18} When “officers have probable cause to search a lawfully stopped vehicle,

they may conduct a warrantless search of any containers found inside that may conceal

the object of the search.” United States v. Johns, 469 U.S. 478, 479-480 (1985). So, if

officers have “probable cause to search for contraband in a car, it is reasonable for

police officers . . . to examine packages and containers without a showing of

individualized probable cause for each one.” Wyoming v. Houghton, 526 U.S. 295,

302 (1999).

{¶19} Booker argues1 that the automobile exception does not apply because

before Bravo’s dog sniff, the officers lacked probable cause to believe there was

1 Booker does not argue that the rifle could not have fit in the bookbag, a closer question.

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evidence of a crime. We disagree. Williamson’s testimony and video footage showed a

gunman with a bookbag and his accomplice taking cover near the trunk of the SUV,

opening a door, and then disappearing into a nearby alley without the rifle and

bookbag. Based on the totality of the circumstances, there was probable cause to

believe that the SUV, and one of the bags inside, held evidence related to a crime.

{¶20} In support of his claim, Booker relies on our opinion in Ward. There,

an “officer saw a vehicle parked near a sidewalk [in an area of high-drug activity] with

a person leaning into the vehicle, and as the officer approached, the person walked

away from the car.” Ward, 2017-Ohio-8141, at ¶ 26 (1st Dist.). We ruled that presence

in a high-crime area combined with neutral or ambiguous acts does not create

probable cause to believe that evidence of a crime exists. Id. at ¶ 19, 26. But Ward is

distinguishable from this case because here, officers knew that a gunman carrying a

bookbag had fired a rifle multiple times before taking cover near the SUV, where he

potentially discarded his rifle and bookbag. Firing a rifle in an urban center and then

fleeing are neither neutral nor ambiguous acts.

{¶21} Booker also argues that the Ohio Supreme Court’s opinion in Burroughs

demands the suppression of the methamphetamine. In Burroughs, the Court

considered the constitutionality of a search of a “closed bookbag with part of a plastic

baggie caught in the zipper” as officers executed an arrest warrant in a home.

Burroughs, 2022-Ohio-2146, at ¶ 3-5. The State argued that the search was

constitutional under “[t]he single-purpose-container exception . . . an offshoot of the

plain-view doctrine.” Id. at ¶ 15. The plain-view exception allows officers to seize an

object in plain view if an officer is lawfully in a place with lawful access to an object in

which its incriminating nature “is immediately apparent.” Horton v. California, 496

U.S. 128, 136-137 (1990). The single-purpose-container exception allows officers to

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OHIO FIRST DISTRICT COURT OF APPEALS

search a container with a distinct “outward appearance” that “proclaims its contents.”

Robbins v. California, 453 U.S. 420, 427 (1981) (plurality opinion), overruled on other

grounds by United States v. Ross, 456 U.S. 798, 824 (1982).

{¶22} The Burroughs Court held that the single-purpose-container exception

did not justify the warrantless search of the bookbag. See Burroughs at ¶ 21. To fall

within the single-purpose-container exception, “‘a container must so clearly announce

its contents, whether by its distinctive configuration, its transparency, or otherwise,

that its contents are obvious to an observer.’” Id. at ¶ 19, quoting Robbins at 428. The

Court reasoned that a bookbag is “commonly used to carry a wide variety of items” and

does not inherently broadcast its contents. Id. at ¶ 20.

{¶23} Williamson agreed that the methamphetamine was found in an

unremarkable and common black bookbag. But Williamson did not rely on the singlepurpose-container exception or suggest that the bookbag announced the

methamphetamine inside. And unlike the bookbag in Burroughs, the facts known to

the officers investigating the gunman gave rise to an inference that the bags in the SUV

were connected to a recent shooting.

{¶24} Booker also points out that the SUV was parked, a fact that he claims

undermines the notion that the SUV’s inherent mobility justified the automobile

search. In this regard, the “‘ready mobility’ of vehicles served as the core justification

for the automobile exception for many years.” Collins v. Virginia, 584 U.S. 586, 591

(2018). And when that mobility or other “justifications for the automobile exception

‘come into play,’ officers may search an automobile without having obtained a warrant

so long as they have probable cause to do so.” Id. But the automobile exception applies

to parked vehicles. See State v. Underwood, 2004-Ohio-504, ¶ 19 (12th Dist.). Indeed,

justifications for the automobile exception apply regardless of whether “the car has

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OHIO FIRST DISTRICT COURT OF APPEALS

been immobilized,” whether “the car would have been driven away,” or whether “its

contents would have been tampered with” while officers secured a warrant. Michigan

v. Thomas, 458 U.S. 259, 261 (1982).

{¶25} Finally, Booker appears to argue that the dog sniff was unconstitutional

since Bravo was not trained to detect firearms and nothing suggested that the SUV

contained narcotics. But we hold that the dog sniff did not violate Booker’s Fourth

Amendment rights because a free-air dog sniff around a car parked on a public road is

not a search under the Fourth Amendment. See Illinois v. Caballes, 543 U.S. 405, 409

(2005); see also State v. Bryner, 2018-Ohio-3215, ¶ 15 (9th Dist.). Dog sniffs “reveal[]

no information other than the location of a substance that no individual has any right

to possess” and “do[] not expose noncontraband items that otherwise would remain

hidden from public view.” Caballes at 409-410.

{¶26} In sum, the officers’ search of the bookbag was constitutional under the

automobile exception because the officers had probable cause to suspect that the

bookbag held evidence in connection with a criminal offense. We overrule Booker’s

first assignment of error.

B. Second Assignment of Error: The trial court’s plea colloquy complied with Crim.R. 11

{¶27} Booker maintains that the trial court failed to accurately advise him of

the maximum penalties that he faced during the plea colloquy as required by Crim.R.

11(C). He contends that the trial court’s alleged misstatement regarding the mandatory

nature of his sentence rendered his no-contest plea unknowing and unintelligent.

{¶28} When a criminal defendant pleads guilty or no-contest to a felony

offense, before accepting the plea, a trial court must advise the defendant of

constitutional and nonconstitutional rights as instructed by Crim.R. 11. See State v.

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OHIO FIRST DISTRICT COURT OF APPEALS

Walker, 2024-Ohio-6079, ¶ 22 (1st Dist.). Nonconstitutional requirements found in

Crim.R. 11(C)(2)(a) and (b) “require the trial court to provide information and make

determinations that help to ensure the defendant’s decision to plead is knowing,

intelligent, and voluntary in a more general sense.” Id. at ¶ 23.

{¶29} Under Crim.R. 11(C)(2)(a), a trial court hearing a no-contest plea to a

felony offense must advise the defendant of “the maximum penalty involved, and if

applicable, that the defendant is not eligible for probation or for the imposition of

community control sanctions at the sentencing hearing.”

{¶30} Relevant here, the trial court discussed the penalties that Booker faced

for each offense, reviewed Ohio’s indefinite-sentencing scheme, and confirmed that

Booker understood that he faced a mandatory prison sentence and was ineligible “for

probation.” Booker maintains that he was not subject to a mandatory prison sentence

and that this misstatement violated Crim.R. 11.

{¶31} But the trial court got it right. Booker was charged with aggravated drug

trafficking in violation of R.C. 2925.03(A)(2), a first-degree felony. Aggravated drug

trafficking is a first-degree felony and carries a mandatory prison sentence if (1) “the

amount of the drug involved equals or exceeds five times the bulk amount but is less

than fifty times the bulk amount” and (2) “the offense was committed in the vicinity of

a school.” R.C. 2925.03(C)(1)(d). Methamphetamine is a schedule II-controlled

substance. See Adm.Code 4729:9-1-02(C)(2). The “bulk amount” for

methamphetamine is three grams. See R.C. 2925.01(D)(1)(g). The “vicinity of a school”

is “within one thousand feet of the boundaries of any school premises.” R.C.

2925.01(P). So, a prison sentence was mandatory so long as Booker pleaded no contest

to an offense involving more than 15 grams of methamphetamine that occurred within

1,000 feet of a school.

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{¶32} At the hearing, the State explained that officers found 16.261 grams of

methamphetamine in the bookbag, which was located 550 feet away from a school.

Because Booker had more than five times the bulk amount of methamphetamine in

the vicinity of a school, a prison sentence was mandatory under R.C. 2925.03(C)(1)(d).

Therefore, the trial court’s advisement complied with Crim.R. 11(C)(1)(a). We overrule

the second assignment of error.

III. Conclusion

{¶33} We overrule Booker’s two assignments of error and affirm the trial

court’s judgment.

Judgment affirmed.

KINSLEY, P.J., and NESTOR, J., concur.

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