Middleburg Hts. v. Wojciechowski, 2015 Ohio 3879

Defendant Richard Wojciechowski was charged with OVI, prohibited BAC, and weaving after Officer Nagy stopped his truck and administered field sobriety and breath tests. Defendant pleaded no contest after the trial court denied his motion to suppress.
Nagy testified he observed the truck weaving and recorded the driving on his dash camera; he said the vehicle crossed lane lines multiple times north of Bagley Road.
The dash camera preserves the prior three minutes when the officer presses record; the recording was played at the suppression hearing.
On cross-examination, Nagy pointed to moments in the video where he said the truck crossed lane lines, but the appellate court reviewed the entire video and found no instance of the vehicle crossing a lane line.
The trial court denied the suppression motion based solely on Nagy’s testimony; the court of appeals found inconsistency between the testimony and the video and held the denial was not supported by competent, credible evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable suspicion to stop the vehicle	Officer (prosecution) argued Nagy observed weaving/crossing lane lines providing reasonable suspicion	Wojciechowski argued Nagy lacked reasonable suspicion because video did not show any lane crossings	Court reversed: video contradicted officer's testimony; stop lacked reasonable suspicion and suppression should have been granted
Whether trial court’s factual findings on suppression are entitled to deference	Prosecution relied on trial court’s acceptance of officer testimony	Defendant challenged factual findings as against the manifest weight given the dash cam recording	Court held appellate review must accept trial court facts if supported by credible evidence; here the video undermined credibility, so deference rejected
Admissibility of breath test and other post-stop evidence (related claims)	Prosecution maintained post-stop evidence admissible because stop was lawful	Defendant argued all evidence should be suppressed as fruit of unlawful stop	Court found these issues moot after ruling stop unlawful (suppression granted)
Whether discrepancies between testimony and recording mandate suppression	Prosecution relied on officer’s testimony over recording	Defendant argued recording controlled and showed no violation	Court held recording contradicted testimony; trial court lacked competent, credible evidence to deny suppression

Mapp v. Ohio, 367 U.S. 643 (Fourth Amendment protections against unreasonable searches and seizures applied to states)
Terry v. Ohio, 392 U.S. 1 (Investigative stops require reasonable, articulable suspicion)
Delaware v. Prouse, 440 U.S. 648 (Traffic stops are seizures under the Fourth Amendment)
State v. Mays, 119 Ohio St.3d 406 (Drifting across lane markings can supply reasonable suspicion; movement within a lane may be insufficient)
State v. Burnside, 100 Ohio St.3d 152 (Standard of appellate review for suppression findings)
State v. Robinette, 80 Ohio St.3d 234 (Ohio Constitution affords similar protections to the Fourth Amendment)
State v. Andrews, 57 Ohio St.3d 86 (Totality-of-the-circumstances test for stops)
State v. Curry, 95 Ohio App.3d 93 (Trial court serves as factfinder in suppression hearings)
State v. Hodge, 147 Ohio App.3d 550 (Inconsequential movement within a lane does not automatically justify a stop)
State v. Fanning, 1 Ohio St.3d 19 (Appellate courts must accept trial court factual findings if supported by competent, credible evidence)