State v. Billups, 2017 Ohio 4309

Officers in uniform in a marked cruiser observed Billups leave a store and initiated a traffic stop for an improper change of course and excessively tinted windows.
During the stop officers approached the vehicle multiple times, tested the tint, ran Billups’s record (revealing prior drug and weapons charges), and began preparing a citation and contact card.
While approaching a third time (about 13–14 minutes into the stop), an officer observed a bulge in Billups’s left front pants pocket and asked him to exit the vehicle.
The officer conducted a Terry pat‑down, felt a large lump in the seat of Billups’s pants, and—relying on plain feel and experience—seized drugs and money; Billups was arrested.
A drug‑sniffing dog arrived around that time and alerted to the driver’s side; a vehicle search yielded baggies, rubber bands, and “pay and owe” forms; Billups was charged with trafficking and possession of heroin.
Billups moved to suppress; the trial court denied the motion. He pled no contest and was sentenced to four years for trafficking; this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable suspicion to perform a Terry pat‑down	Officer had reasonable suspicion based on furtive movements, nervousness, observed bulge, and Billups’s record	Billups argued officers lacked reasonable suspicion for a weapons frisk	Held: Reasonable suspicion existed; frisk was lawful under Terry
Whether pat‑down exceeded Terry scope / plain‑feel seizure valid	Seizure lawful because officer immediately recognized contraband by plain feel and did not manipulate	Billups argued officer exceeded scope by effectively searching for evidence, not just weapons	Held: Plain‑feel applied; seizure permissible (no impermissible probing)
Whether stop was unlawfully prolonged by waiting for drug dog (Rodriguez)	State: officers were still performing traffic‑stop tasks (paperwork, tint test, running record); no unlawful extension	Billups: officers detained him 13–14 minutes to await canine, extending the stop beyond traffic purposes	Held: No unlawful prolongation; activities were within traffic‑stop mission and dog arrival did not add unlawful time
Whether officers had probable cause to arrest after discovering contraband	State: discovery of drugs during pat‑down supplied probable cause for arrest	Billups: arrest lacked probable cause because seizure was unlawful	Held: Probable cause existed once contraband was plainly discovered during the lawful pat‑down

Terry v. Ohio, 392 U.S. 1 (establishes officer may frisk for weapons if reasonable suspicion of danger)
Minnesota v. Dickerson, 508 U.S. 366 (plain‑feel doctrine permits seizure of contraband immediately apparent during lawful frisk)
Rodriguez v. United States, 135 S. Ct. 1609 (traffic stop may not be extended beyond tasks related to the stop absent reasonable suspicion)
State v. Burnside, 100 Ohio St.3d 152 (standard of review for suppression rulings: deference to trial court’s factual findings)
State v. Evans, 67 Ohio St.3d 405 (frisk more readily justified where suspects are believed to be involved in drug trafficking)
State v. Milhouse, 133 Ohio App.3d 527 (Terry frisk exceeded when officer manipulated object to identify narcotics under crotch area)