State v. Atkins, 2013 Ohio 2446

Defendant Holly Atkins was cited July 3, 2012 for DUI and BAC over limit and a marked lanes violation; she pleaded not guilty at arraignment.
A suppression hearing occurred September 14, 2012; defense challenged the stop as based on an anonymous tip.
Trooper Moran testified a dispatcher relayed a caller following Atkins’ eastbound I-70 vehicle, describing erratic driving and a near-median risk.
The caller identified as Ann; a passenger named Duane was later confirmed by Moran; caller remained on the line with dispatch.
Moran stopped Atkins for a marked lanes violation after a solid-white-line lane change, based on the dispatcher’s tip rather than observed driving.
The trial court denied suppression; Atkins pleaded no contest to DUI-related offenses and the marked lanes charge was dismissed; she was fined and licensed suspended.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop justified by reasonable suspicion from the tip?	State argues the identified citizen tip provided reasonable suspicion.	Atkins argues anonymous tip lacks corroboration and reliability.	Yes; stop sustained; tip identified as credible with ongoing contact.

United States v. Cortez, 449 U.S. 411 (U.S. Supreme Court 1981) (establishes reasonable suspicion standard for investigative stops)
Alabama v. White, 496 U.S. 325 (U.S. Supreme Court 1990) (anonymous tips may require corroboration; minimal justification needed)
Illinois v. Wardlow, 528 U.S. 119 (U.S. Supreme Court 2000) (requires a minimal level of objective justification for stops)
Weisner, 87 Ohio St.3d 295 (Ohio 1999) (informant reliability considerations and citizen tip credibility)
Gates v. Illinois, 462 U.S. 213 (U.S. Supreme Court 1983) (totality of circumstances in evaluating informant tips)