State v. Brown, 2021 Ohio 2193

Maurice Brown was charged with possession of drug paraphernalia after a K-9 alert and a search of his parked car found a digital scale with cocaine residue.
Undercover Officer Sullivan had been surveilling the UR Mart for 2–3 months because of frequent hand‑to‑hand crack‑cocaine transactions.
Sullivan observed a known suspect in a red pickup conduct a hand‑to‑hand drug transaction and then leave; Brown was parked behind that truck and followed it out of the lot.
Sullivan observed Brown “slow‑roll” past a traffic stop of the pickup and look toward the officers; Sullivan suspected Brown was conducting counter‑surveillance for dealers.
Uniformed officers stopped Brown (no traffic violation observed), waited ~18 minutes for a K‑9, the dog alerted, and contraband was found; Brown moved to suppress as the stop and detention lacked reasonable suspicion.
The municipal court granted suppression; the state appealed and the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did officers have reasonable, articulable suspicion to stop and detain Brown for drug investigation?	Sullivan’s observation that Brown followed the buyer, slow‑rolled, and looked at officers amounted to counter‑surveillance—together with Sullivan’s narcotics expertise—gave reasonable suspicion to stop.	No observed traffic violation or hand‑to‑hand transaction; Sullivan never saw Brown at the Mart before and had no specific facts tying Brown to the dealers—the stop was an inarticulate hunch.	The stop and detention were not supported by reasonable suspicion. Officer’s experience‑based hunch and Brown’s proximity/behavior were insufficient; suppression affirmed.

Terry v. Ohio, 392 U.S. 1 (establishes reasonable‑articulable‑suspicion standard for temporary stops)
State v. Bobo, 37 Ohio St.3d 177 (Ohio case applying Terry standard to investigatory detentions)
State v. Freeman, 64 Ohio St.2d 291 (courts assess stops under the totality of the circumstances)
State v. Jones, 70 Ohio App.3d 554 (an officer may not rely on an inarticulate hunch to satisfy Terry)
United States v. Del Vizo, 918 F.2d 821 (extensive, corroborated patterns and counter‑surveillance can support probable cause)