In re J.C., 2019 Ohio 4815

J.C., a 17‑year‑old, was seen by Officer Pat Kemper three times in one day; each time J.C. glanced down and put his right hand near his right hip upon seeing the marked cruiser.
Officer Kemper, patrolling a neighborhood he described as extremely violent with frequent gun incidents, concluded from those repeated hand‑to‑waist movements that J.C. might be concealing a firearm.
After returning to the area, Kemper and Sergeant Downs parked their cruisers on the sidewalk, blocking the juveniles’ path; the officers ordered the four boys to the ground, handcuffed J.C., and Kemper’s pat‑down recovered a loaded revolver.
J.C. was charged with carrying a concealed weapon (R.C. 2923.12) and a probation violation; he moved to suppress the firearm and ammunition, but the juvenile court denied suppression and adjudicated him delinquent.
On appeal the First District held the initial stop lacked reasonable, articulable suspicion under Terry, reversed the denial of the suppression motion, reversed the adjudication, and discharged J.C.

Issue	State's Argument	J.C.'s Argument	Held
Whether officers had reasonable suspicion to seize/stop J.C.	Repeated hand‑to‑waist movements on three encounters, officer training/experience, juvenile status, and high‑crime area objectively supported suspicion that he was armed.	Movements were innocuous and amounted to an inarticulate hunch; no corroborating facts (bulge, metal, tip, or matching suspect description).	No reasonable suspicion; stop was unconstitutional.
Whether the protective pat‑down/search was lawful	A Terry protective frisk is permitted where officer reasonably believes person may be armed and dangerous.	Because the stop was unlawful, any subsequent frisk/search was invalid.	Because the stop lacked reasonable suspicion, the evidence from the frisk must be suppressed.
Disposition of related convictions (weapon / probation)	Evidence supported adjudication.	Suppressed evidence undermines convictions.	Suppression dispositive; other assignments of error mooted; adjudications reversed and J.C. discharged.

Terry v. Ohio, 392 U.S. 1 (established stop‑and‑frisk standard requiring reasonable, articulable suspicion)
United States v. Mendenhall, 446 U.S. 544 (defining seizure and when encounter becomes a Fourth Amendment seizure)
United States v. Cortez, 449 U.S. 411 (totality‑of‑circumstances inquiry for reasonable suspicion)
United States v. Arvizu, 534 U.S. 266 (courts must give weight to officers’ experience and training in evaluating suspicion)
Illinois v. Wardlow, 528 U.S. 119 (Terry stops accept some risk of stopping innocent persons; flight and evasive behavior relevant)
State v. Andrews, 57 Ohio St.3d 86 (reasonable‑suspicion analysis viewed through the eyes of a reasonable, prudent officer on the scene)
State v. Bobo, 37 Ohio St.3d 177 (high‑crime area is a relevant but not dispositive factor)