State v. Brown, 2012 Ohio 5532

Officers Sult and Simon, Grandview Hospital Police, patrolled near Grandview Hospital in Dayton under a Mutual Aid Agreement.
Brown rode a bicycle without lights, a minor violation under Dayton ordinances, leading officers to stop him.
Officer Sult asked Brown for ID and inquired about weapons, and Brown admitted he possessed a weapon.
Officer Sult ordered Brown to the ground at gunpoint; a handgun was removed from Brown’s back pocket and ammo found in another pocket.
Brown was charged with carrying a concealed weapon; he moved to suppress evidence, the trial court granted, and the State appeals seeking reversal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop for riding without a light was a routine stop not requiring Miranda warnings.	Brown's stop was a permissible routine stop; no Miranda warnings required.	The stop and questioning were custodial and required Miranda warnings.	Stop constituted routine traffic stop; Miranda not required.
Whether asking about weapons during a traffic stop is permissible without reasonable suspicion.	Asking about weapons is permissible and not a search.	A weapon inquiry without suspicion could be improper.	Questioning about weapons allowed; leads to reasonable suspicion after admission.
Whether the gun seized during the patdown was properly seized under Terry after Brown admitted possession.	Admission of weapon creates suspicion justifying a patdown for weapons.	Evidence suppression should stand due to lack of warranted suspicion.	Gun discovery proper; suppression reversed.

Berkemer v. McCarty, 468 U.S. 420 (U.S. Supreme Court 1984) (noncustodial routine stops default to no Miranda warnings)
Pennsylvania v. Bruder, 488 U.S. 9 (U.S. Supreme Court 1984) (noncustodial questioning during traffic stops not Miranda-triggering)
State v. Roberts, 2010-Ohio-300 (Ohio 2d Dist. Montgomery 2010) (traffic-stop suspicion standard for stops closely related to minor violations)