State v. Brown, 143 Ohio St. 3d 444

On March 16, 2011, a Lake Township police officer, Kelly Clark, observed a Chevy Impala briefly cross the fog line on I‑280 and stopped the car about 2.5 miles later.
Clark was a township officer who lacked statutory authority under R.C. 4513.39 to stop motorists for marked‑lane violations on interstate highways; she nonetheless conducted the stop and used a drug dog, yielding oxycodone and marijuana.
Brown was charged with aggravated possession; the trial court denied his suppression motion and he pleaded no contest and was sentenced to three years.
The Sixth District reversed, holding the extraterritorial stop violated Article I, Section 14 of the Ohio Constitution and ordering suppression of the evidence; the state appealed.
The Ohio Supreme Court affirmed: because the township officer acted without statutory authority to stop for a minor misdemeanor on an interstate, the stop, arrest, and search violated Article I, Section 14 and the evidence should have been suppressed.

Issue	Brown's Argument	State's Argument	Held
Whether a traffic stop made without statutory jurisdiction violates Article I, Section 14 of the Ohio Constitution	The stop violated Ohio Constitution; state statute denies township officers authority to enforce marked‑lane violations on interstates, so evidence must be suppressed	Ohio and federal search‑and‑seizure protections are coextensive; probable cause renders an extraterritorial stop reasonable under the Fourth Amendment, so Article I, §14 should not be broader	A stop for a minor misdemeanor made outside an officer’s statutory jurisdiction violates Article I, §14; suppression required
Whether a statutory violation (R.C. 4513.39) alone can trigger exclusion under Article I, §14	Statutory limit on officer power renders the stop unconstitutional — exclusionary rule applies	A statute’s violation alone does not necessarily create a constitutional violation; federal precedent (Atwater/Moore) supports upholding stops based on probable cause	Court held statutory violation here did rise to a constitutional violation under Article I, §14 because officer lacked authority; exclusionary remedy ordered

State v. Brown, 99 Ohio St.3d 323 (2003) (Ohio Constitution provides greater protection than Fourth Amendment against warrantless arrests for minor misdemeanors)
State v. Jones, 88 Ohio St.3d 430 (2000) (balancing test for reasonableness under Ohio Constitution)
State v. Jones, 121 Ohio St.3d 103 (2009) (probable cause suffices for extraterritorial traffic stop under Fourth Amendment)
State v. Holbert, 38 Ohio St.2d 113 (1974) (statute precluding township enforcement of enumerated traffic laws bars stops/arrests)
Atwater v. Lago Vista, 532 U.S. 318 (2001) (Fourth Amendment permits arrest for minor misdemeanor if officer has probable cause)
Virginia v. Moore, 553 U.S. 164 (2008) (probable cause conclusively establishes constitutional reasonableness of arrest)
State v. Robinette, 80 Ohio St.3d 234 (1997) (Ohio and federal protections treated as coextensive in search‑and‑seizure analysis)