State v. Halczyszak

In State v. Halczyszak (1986), 25 Ohio St.3d 301, 25 Ohio B. 360, 496 N.E.2d 925, the Ohio Supreme Court held that "the 'immediately apparent' requirement of the 'plain view doctrine' is satisfied when police have probable cause to associate an object with criminal activity. In ascertaining the required probable cause to satisfy the 'immediately apparent' requirement, police officers may rely on their specialized knowledge, training, and experience."