State v. Baughman, 947 N.E.2d 1273

Officer Martin stopped Shawna Baughman based solely on an identified-citizen tip after identifying the vehicle and plate supplied by a 9-1-1 caller.
The tipster claimed the red Pontiac was driving erratically and possibly intoxicated; the officer had no observed traffic violations before the stop.
Shawna admitted to drinking one beer; she was arrested and transported to the station where BAC testing occurred.
At suppression, the defense argued Frank Baughman’s tip was unreliable and there was no independent observation of impairment, rendering the stop invalid.
Frank, who had contacted 9-1-1 under a false name, was later revealed to be Shawna’s husband; he did not actually observe the driving behavior he reported.
The trial court granted suppression, excluding all evidence obtained from the stop and subsequent testing; the state appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was valid under Fourth Amendment because based on a reliable tip.	Baughman argues tip was from an identified-citizen informant and sufficient to justify the stop.	Shawna contends the tip was unreliable and the stop lacked independent corroboration.	Stop for lack of independent observation was supported by a valid identified-citizen tip; suppression reversed.

Maumee v. Weisner, 87 Ohio St.3d 295 (1999) (identified-citizen tips can support stops with reliability considerations)
United States v. Hensley, 469 U.S. 221 (1985) (reasonable suspicion for investigative stops)
Terry v. Ohio, 392 U.S. 1 (1968) (reasonable and articulable suspicion standard)
Illinois v. Gates, 462 U.S. 213 (1983) (reliability of informants and totality of circumstances)
United States v. Leon, 468 U.S. 897 (1984) (exclusionary rule deterrence and police culpability analysis)
Herring v. United States, 555 U.S. 135 (2009) (exclusionary rule applicability based on reasonable police reliance)