State v. Bullock
85 N.E.3d 133
Ohio Ct. App.2017Background
- In early morning Feb. 4, 2016, Deputy Traevon Williams observed Aaron Bullock driving on State Route 730 with his right-turn signal on but not turning; Bullock continued ~300+ feet.
- Bullock pulled over, stopped straddling the white line for ~30 seconds with signal still on, then re-entered the road and immediately made an un-signaled left, drove off the road into a field and into a driveway.
- Deputy Williams activated his cruiser lights and made a traffic stop because he was concerned Bullock might be impaired or suffering a medical problem.
- Bullock was cited for OVI (R.C. 4511.19) and filed a motion to suppress, arguing the traffic stop violated the Fourth Amendment.
- The municipal court granted the motion to suppress, finding no exception to the Fourth Amendment; the State appealed.
- The Twelfth District reversed, holding the officer had at least reasonable, articulable suspicion to conduct an investigatory (Terry) stop based on the totality of the observed driving behavior.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was lawful under the Fourth Amendment (probable cause or reasonable suspicion for an investigatory stop) | The State: Deputy Williams had reasonable, articulable suspicion (based on odd driving—signal on, long pass, stopping straddling line, then driving off road into a field) to initiate an investigative stop | Bullock: stop was unlawful; no exception to the Fourth Amendment justified the stop | Court: Reversed suppression — Deputy Williams had, at minimum, reasonable and articulable suspicion to make a lawful investigatory (Terry) stop; remanded for further proceedings |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (probable-cause traffic-stop standard)
- Terry v. Ohio, 392 U.S. 1 (Terry investigatory-stop reasonable-suspicion standard)
- Illinois v. Gates, 462 U.S. 213 (probable cause defined as a probability or substantial chance)
- State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression rulings)
- State v. Batchili, 113 Ohio St.3d 403 (totality-of-circumstances for reasonable suspicion)
- State v. Bobo, 37 Ohio St.3d 177 (officer perspective/experience considered in stop analysis)