State v. Belvin, 2014 Ohio 3634

On July 1, 2013, Belvin made a U-turn from the left-turn lane on Needmore Road at Northcrest Drive; officers nearby believed the maneuver was illegal because it occurred on the approach to a graded curve where a vehicle might not be seen within 500 feet.
Officers followed Belvin to a nearby gas station, stopped his vehicle, and shortly after approaching observed a loaded shotgun on the floor behind the front seats.
Belvin was charged with improper handling of a firearm in a motor vehicle (R.C. 2923.16), a fourth-degree felony; he moved to suppress the gun arguing the traffic stop lacked probable cause.
The trial court denied the suppression motion, finding the officers had probable cause (and at least reasonable suspicion) to stop Belvin for violating the U-turn statute, and that the gun was in plain view.
Belvin pled no contest, was convicted, and received mandatory community control; appellate counsel filed an Anders brief arguing no meritorious issues, identifying only the suppression claim.
The appellate court independently reviewed the record, concluded the stop was justified, found the appeal frivolous, and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the traffic stop justified under R.C. 4511.37(A) / Terry?	Officers (State) argued they observed an illegal U-turn on the approach to a grade/curve, giving reasonable suspicion/probable cause to stop.	Belvin argued oncoming traffic could see his vehicle beyond 500 feet, so no statutory violation and no reasonable suspicion for the stop.	Court held the officer’s observations and area topography supported a reasonable officer’s belief that a violation occurred; stop was justified.
Was the shotgun seizure a Fourth Amendment violation?	State: Gun was in plain view during a lawful stop, so seizure was lawful.	Belvin: Seizure impermissible because the stop lacked justification.	Court held the stop lawful and the gun was in plain view; no Fourth Amendment violation.

Anders v. California, 386 U.S. 738 (1967) (requires counsel to file brief identifying any arguable issues when claiming appeal is frivolous)
Penson v. Ohio, 488 U.S. 75 (1988) (appellate court must conduct independent review when counsel files an Anders brief)
Terry v. Ohio, 392 U.S. 1 (1968) (police may stop and briefly detain for investigatory purposes with reasonable, articulable suspicion)
Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (traffic stops permitted when officer has reasonable and articulable suspicion of a traffic offense)
State v. Andrews, 57 Ohio St.3d 86 (1991) (totality-of-circumstances standard for evaluating reasonable suspicion)