State v. Andrews
2017 Ohio 1383
| Ohio Ct. App. | 2017Background
- Trooper Miranda stopped Artis Andrews after observing him allegedly exceed the speed limit and briefly leave his lane (trooper testified right tire crossed the lane by ~½ tire width) and make a late left turn into the turn lane.
- Miranda asked for Andrews’ identification; he could not produce it and was placed in the trooper’s cruiser while she verified his identity.
- Miranda detected a strong odor of alcohol, red/glassy eyes, inconsistent statements about where Andrews had been, and noted balance problems when he sat on a wall.
- Miranda administered standardized field sobriety tests (HGN, walk-and-turn, one-leg stand), testified Andrews failed them, and arrested him for OVI.
- Andrews moved to suppress: arguing the marked-lanes stop lacked reasonable suspicion (video showed only touching the line and a road bump), the FSTs were not justified, and statements made while in the cruiser required Miranda warnings because he was effectively in custody.
- The trial court credited the trooper’s testimony over the dash-cam (poor video quality), denied suppression, and the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Andrews) | Held |
|---|---|---|---|
| Whether trooper had reasonable, articulable suspicion to stop for a marked-lanes violation | Trooper observed tire cross the dashed white by ~½ tire width and later cross a solid line into the turn lane; officer testimony credible despite low-quality video | Dash-cam objectively shows only touching the line; any contact was caused by a road bump and did not constitute a marked-lanes violation | Stop was lawful: court credited trooper; de minimis crossing that leaves lane supports reasonable suspicion under R.C. 4511.33 and controlling precedent (Mays/Batchili) |
| Whether trooper had reasonable suspicion to detain and administer field sobriety tests for OVI | Totality (lane violation, strong odor of alcohol, red/glassy eyes, late-night from bars, failed/poor balance during instructions, evasive answers) justified detention and FSTs | Odor alone (or de minimis lane contact) is insufficient; Andrews was calm, not slurring, and dash-cam showed no obvious impairment like stumbling | Court held totality gave reasonable, articulable suspicion to investigate for OVI and to administer FSTs |
| Whether Miranda warnings were required when officer placed Andrews in cruiser to verify identity | Vehicle identification detention to verify identity is a Terry-type detention, not custodial; not handcuffed, not told under arrest | Placement in cruiser while officer knew license was suspended made a reasonable person feel in custody; therefore questioning required Miranda warnings | Court held the identity-verification detention was noncustodial (no Miranda violation) |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (Terry stop standard: specific, articulable facts to justify brief investigative detention)
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (traffic stops require reasonable, articulable suspicion)
- Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (distinguishes roadside investigatory stops from custodial interrogations for Miranda purposes)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (de minimis traffic violations can supply objective justification for stops)
- State v. Batchili, 113 Ohio St.3d 403 (Ohio 2007) (discusses reasonable-suspicion analysis for traffic stops)
- State v. Mays, 119 Ohio St.3d 406 (Ohio 2008) (officer may constitutionally stop a motorist observed drifting over lane markings)