State v. Barnett
114 N.E.3d 773
Ohio Ct. App.2018Background
- Around 1:00 a.m. on Oct. 11, 2016, Youngstown officers followed Rufus Barnett for ~200 yards and observed him enter an intersection where Oak Hill ends at Mahoning.
- A sign at the intersection labeled the right lane as a straight-bound lane; a separate sign read “No Turn on Red.” Barnett entered the right lane, stopped at a red light, then activated his right turn signal after the light turned green and proceeded onto Mahoning.
- Officers stopped Barnett for allegedly violating R.C. 4511.39 (failure to signal 100 feet before turning). Barnett produced no license; LEADS showed an FRA suspension. He was frisked, placed in the cruiser, his car was impounded, and an inventory search uncovered suspected heroin.
- Barnett moved to suppress the evidence, arguing he was not required to signal because his lane was posted as straight-bound; alternatively he argued his arrest was unlawful. The state argued the stop and inventory search were lawful and asserted good-faith and attenuation defenses.
- The trial court granted the suppression; the state appealed. The appellate majority affirmed, holding the posted straight-bound lane eliminated the duty to signal and thus no reasonable suspicion supported the stop. Judge Robb dissented, arguing an objectively reasonable officer could suspect a signal violation (citing Heien and related precedent).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of traffic stop under R.C. 4511.39 (failure to signal) | Officer had reasonable suspicion/probable cause because Barnett negotiated a rightward movement onto Mahoning without signaling 100 feet before the turn | Barnett was in a lane posted as straight-bound and therefore was not required to signal; the stop was unlawful | Held: No reasonable suspicion — posted straight-bound lane meant no duty to signal, so stop unlawful |
| Applicability of good-faith / objectively reasonable mistake of law (Heien) | Even if mistaken, officers acted reasonably in stopping Barnett; good-faith exception or reasonable mistake of law justifies the stop | A correct reading of the statute and the presence of a conforming traffic-control device made an objectively reasonable officer not conclude a violation occurred | Held: Good-faith / reasonable-mistake arguments rejected — officers’ belief was not objectively reasonable given the traffic control device indicating straight-bound lane (state waived attenuation argument) |
| Lawfulness of impoundment and inventory search | Impoundment and inventory were permitted under municipal code/case law after a lawful stop | Searches and seizure flowed from an unlawful stop; evidence should be suppressed | Held: Because the stop lacked reasonable suspicion, the resulting search and evidence were suppressed |
| Appellate reviewability of attenuation doctrine | State argued attenuation would cure any taint | State did not raise attenuation before the trial court; appellate court declined to consider it | Held: Attenuation argument forfeited on appeal and not considered |
Key Cases Cited
- State v. Mays, 119 Ohio St.3d 406 (Ohio 2008) (reasonable and articulable suspicion standard for traffic stops; totality-of-circumstances review)
- Heien v. North Carolina, 574 U.S. 54 (2014) (reasonable mistake of law can supply reasonable suspicion if objectively reasonable)
- Delaware v. Prouse, 440 U.S. 648 (1979) (constitutional protections against unreasonable stops; stopping requires reasonable suspicion)
- State v. Burnside, 100 Ohio St.3d 152 (Ohio 2003) (appellate review standards for suppression: trial court factual findings afforded deference)
- State v. Batchili, 113 Ohio St.3d 403 (Ohio 2007) (totality-of-circumstances governs reasonable suspicion analysis)
- Bowling Green v. Godwin, 110 Ohio St.3d 58 (Ohio 2006) (officer’s reasonable stopping and citation may be upheld even if defendant could not ultimately be convicted of the traffic offense)