2020 Ohio 713
Ohio Ct. App.2020Background
- At 2:45 a.m., Medina police stopped A.C.’s vehicle after a records check showed her license was under a judgment suspension. No erratic driving or other traffic violations were observed.
- The officer detected a "moderate" odor of alcohol from the vehicle; one passenger appeared passed out and A.C. said the passenger was drunk.
- A.C. admitted she and the occupants had left a nearby bar and that she had two beers earlier.
- The officer asked A.C. to exit the vehicle, spoke with her at the rear, still noticed alcohol odor (unable initially to pinpoint the source), then detained her to perform field sobriety tests.
- The trial court granted A.C.’s motion to suppress evidence from the field sobriety tests for lack of reasonable suspicion to extend the stop; the State appealed.
- The Ninth District reversed: applying the totality of the circumstances, the majority held the officer had reasonable suspicion to detain A.C. for sobriety testing; one judge dissented and would have affirmed suppression.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (A.C.) | Held |
|---|---|---|---|
| Whether the officer had reasonable, articulable suspicion to prolong the traffic stop to administer field sobriety tests | The totality of the circumstances (time, proximity to bar, admission of drinking, moderate alcohol odor, passed-out passenger) gave reasonable suspicion to detain and test A.C. | The facts (stop for license suspension, no erratic driving, cooperative behavior, no slurred speech, no bloodshot eyes, odor possibly originating from other occupants) did not amount to reasonable suspicion to prolong the stop | Reversed suppression: the court held the officer had reasonable suspicion under the totality of the circumstances and could detain A.C. for field sobriety testing; one judge dissented |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (establishes stop-and-frisk reasonable, articulable-facts standard)
- Delaware v. Prouse, 440 U.S. 648 (traffic stops constitute seizures that must be reasonable)
- Berkemer v. McCarty, 468 U.S. 420 (traffic stops are seizures subject to Fourth Amendment)
- United States v. Brignoni-Ponce, 422 U.S. 873 (officer must point to specific, articulable facts supporting reasonable suspicion)
- Rodriguez v. United States, 575 U.S. 348 (stop duration limited to mission; extensions require independent reasonable suspicion)
- Arizona v. Arvizu, 534 U.S. 266 (reasonable-suspicion inquiry is based on the totality of the circumstances)
- State v. Batchili, 113 Ohio St.3d 403 (Ohio: prolonging a stop requires reasonable suspicion; evaluate totality)
- State v. Burnside, 100 Ohio St.3d 152 (standard of review for suppression rulings: mixed question of law and fact)
- State v. Mays, 119 Ohio St.3d 406 (traffic stop requires reasonable suspicion that motorist committed or is committing a crime)
- State v. Andrews, 57 Ohio St.3d 86 (courts should give due weight to officer training and experience)