City of Cleveland v. Kalish, 106 N.E.3d 881

At ~11:45 p.m. on I-90, Officer Suda observed Todd Kalish's car cross lane markers several times and change lanes without signaling; he stopped the vehicle.
Only Kalish was in the car; upon approach Suda smelled alcohol coming from the vehicle and observed bloodshot eyes and a flushed face.
Kalish produced documents without difficulty, exited the vehicle promptly, and walked normally to the patrol car; he admitted he had been drinking at an Indians game.
Suda ordered Kalish out (Mimms authority), performed field sobriety tests, and arrested him for OVI.
The municipal court found the initial stop valid but held Suda lacked reasonable, articulable suspicion to expand the stop to administer field sobriety tests and suppressed evidence.
The city appealed; the appellate majority reversed, concluding the totality of the circumstances supported reasonable suspicion to administer field sobriety tests; one judge dissented.

Issue	City’s Argument	Kalish’s Argument	Held
Was the initial traffic stop justified?	Yes — observed lane violations gave probable cause to stop.	The stop was challenged below but not pursued on appeal.	Yes — stop was lawful (lane violations).
Did officer have reasonable, articulable suspicion to expand the stop and administer field sobriety tests?	Yes — lane violations, odor of alcohol from car, bloodshot eyes, flushed face, late hour, and admission of drinking together created reasonable suspicion.	No — post-stop observations showed no coordination problems, no slurred speech, no containers or strong odor on breath, and the flushed face appeared baseline; facts did not support suspicion to expand the stop.	Reversed the suppression: under the totality of circumstances officer had reasonable suspicion to conduct field sobriety tests (close call).

Terry v. Ohio, 392 U.S. 1 (establishes reasonable-suspicion standard for investigative stops)
Pennsylvania v. Mimms, 434 U.S. 106 (officer may order driver out of vehicle during lawful traffic stop)
Dayton v. Erickson, 76 Ohio St.3d 3 (even minor traffic violations justify a stop)
State v. Mays, 119 Ohio St.3d 406 (drifting across lines supports suspicion of lane-law violation)
State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression rulings)
State v. Williams, 51 Ohio St.3d 58 (reasonable, articulable suspicion requirement)
State v. Evans, 67 Ohio St.3d 405 (factors relevant to reasonable suspicion for sobriety investigation)