State v. Brown, 2020 Ohio 896

Defendant Terrance Brown was indicted after officers found firearms in his vehicle following a traffic stop for an allegedly obstructed temporary license placard.
Officer Kemper followed Brown’s car for a few hundred yards, testified the temporary plate cover was tinted and hindered view, then ran the plate after stopping directly behind Brown at a light.
Kemper initiated a traffic stop believing the tinted cover violated R.C. 4503.21; the stop led to discovery of the firearms.
At the suppression hearing, photographs of the covered plate were admitted; the court found the plate characters were ascertainable and the officer’s claim that the cover obstructed the plate lacked credibility.
The trial court granted Brown’s motion to suppress; the state appealed and the appellate court affirmed, holding the stop was not supported by probable cause or reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the traffic stop lawful based on an objectively reasonable belief that Brown’s temporary placard was obstructed?	Officer reasonably believed the tinted cover "obstructed" the placard, giving reasonable suspicion/probable cause to stop.	No obstruction existed; officer could read the plate and "obstructs" requires cutting off visibility.	The officer’s belief was not objectively reasonable; no reasonable suspicion or probable cause; stop unlawful.

State v. Burnside, 100 Ohio St.3d 152, 797 N.E.2d 71 (2003) (standard for appellate review of suppression findings)
Whren v. United States, 517 U.S. 806 (1996) (traffic stops are Fourth Amendment seizures)
Heien v. North Carolina, 574 U.S. 54 (2014) (an officer’s reasonable mistake of law can support reasonable suspicion)
Bowling Green v. Godwin, 110 Ohio St.3d 58, 850 N.E.2d 698 (2006) (reasonable-suspicion/probable-cause judged by objectively reasonable officer)
State v. Mays, 119 Ohio St.3d 406, 894 N.E.2d 1204 (2008) (reasonable suspicion may suffice for investigative traffic stops)