State v. Bizzell, 100 N.E.3d 1267

After midnight on Dec. 13, 2016, Officer Christoffers stopped Bizzell’s pickup for failing to signal 100 feet before a right turn at an intersection near a high-crime neighborhood.
Cruiser-camera video and officer testimony showed Bizzell signaled only just before turning; officer initiated stop and approached the driver’s side.
Bizzell said his license was in another vehicle; officer asked him to exit and, before pat-down, asked if he had any weapons.
Bizzell spontaneously replied there was a gun under the driver’s seat; officer handcuffed him, secured the weapon, towed and inventoried the vehicle, then read Miranda rights and obtained further statements.
Bizzell moved to suppress the gun and statements arguing (1) no legal basis for the stop because video did not show the signal violation, and (2) his statement about the gun was elicited in custody without Miranda.
The trial court denied suppression; Bizzell pleaded no contest to weapons-related felonies and appealed. The appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the traffic stop lawful?	Officer observed a turn-signal violation warranting a stop.	Video does not corroborate a violation; officer targeted the neighborhood.	Stop lawful; video corroborates signaling too late (violated R.C. 4511.39).
Could officer order Bizzell out of vehicle and pat him down?	Officer lawfully ordered exit after no ID; pat-down justified by weapon disclosure and safety concerns.	Officer lacked reasonable basis for a weapons frisk when ordering him out.	Ordering exit permissible; frisk and handcuffing permissible given statement about a gun and nighttime lone-officer context.
Was Bizzell’s statement about the gun protected Miranda custodial statement?	Statement was voluntary and not elicited during custodial interrogation; roadside stop is noncustodial.	Statement occurred after custody-like measures and before Miranda warnings, so inadmissible.	Statement was spontaneous during a traffic stop (noncustodial); not a Miranda violation.
Was the subsequent vehicle search/inventory lawful?	Vehicle inventory/tow policy and the disclosure provided probable cause to search/secure weapon.	Search was pretextual and warrantless; any evidence should be suppressed.	Search and inventory lawful; weapon lawfully recovered and evidence admissible.

Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (routine traffic stops are noncustodial for Miranda purposes)
Whren v. United States, 517 U.S. 806 (U.S. 1996) (traffic violation provides legitimate basis for stop even if pretextual)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (brief investigative stops and limited frisks permitted on reasonable suspicion)
Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (appellate review: factual findings reviewed for clear error, legal application de novo)
Pennsylvania v. Mimms, 434 U.S. 106 (U.S. 1977) (officer may order driver out of vehicle after a lawful stop)
State v. Evans, 67 Ohio St.3d 405 (Ohio 1993) (Mimms does not automatically authorize a weapons frisk; frisk requires reasonable, objective basis)
State v. Andrews, 57 Ohio St.3d 86 (Ohio 1991) (frisk requires reasonable belief suspect is armed and dangerous)