State v. Adams
2015 Ohio 3786
Ohio Ct. App.2015Background
- Appellant State of Ohio appeals a suppression ruling denying its motion to suppress evidence from a traffic stop of appellee Adams.
- Trooper Schack observed a Buick Century driving 65–70 mph on I-70 in light rain with the Buick in the left lane then moving into the right lane in front of a semi-truck.
- Trooper believed the lane change created unsafe spacing (about two car lengths) given speed and conditions, and initiated the stop.
- Adams was identified as the driver; contraband items were found and incriminating statements were made after the stop.
- Appellee moved to suppress, which the trial court granted; the State appealed arguing there was reasonable suspicion for the stop.
- The appellate court affirmed the suppression order, holding there was no reasonable suspicion under the circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was supported by reasonable and articulable suspicion | Adams | Adams | Stop suppressed; no reasonable suspicion shown |
Key Cases Cited
- State v. Mays, 119 Ohio St.3d 406 (Ohio Supreme Court 2008) (establishes reasonable suspicion standard for traffic stops)
- State v. Pierce, 2011-Ohio-2361 (5th Dist. Richland) (car-length rule; supports probable cause for following too closely)
- State v. Johnson, 2004-Ohio-3409 (9th Dist.) (precedent on traffic stop justification caution)
- State v. Kelly, 188 Ohio App.3d 842 (2010-Ohio-3560) (observational basis for stopping vehicle following too closely)
- Ornelas v. U.S., 517 U.S. 690 (U.S. Supreme Court 1996) (emphasizes de novo review of reasonable suspicion and probable cause)