State v. Carnes, 2015 Ohio 379

Trooper Madden stopped Jonathan Carnes after observing him "overshoot" a stop sign, back up, then drive into a parking lot rather than proceed when traffic cleared.
Madden observed red, glassy, bloodshot eyes and an odor of alcohol; Carnes denied drinking, volunteered he was driving on limited privileges from a prior ALS, and declined field-sobriety and chemical testing after requesting counsel.
The trial court found reasonable suspicion to stop and probable cause to arrest; Carnes pleaded no-contest to a traffic-control-device violation and was found not guilty on OVI charges but appealed his administrative license suspension (ALS).
The central question on appeal was whether the arresting officer had "reasonable ground" to believe Carnes operated a vehicle while impaired, the statutory standard for upholding an ALS.
The court reviewed whether "reasonable ground" should be equated to "probable cause," and evaluated the objective indicia of impairment (traffic violation, appearance, odor, suspicious behavior, prior ALS, and refusal to test).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the arresting officer had reasonable ground to impose an ALS	Trooper Madden had reasonable ground/probable cause based on traffic violation, appearance, odor, suspicious conduct, prior ALS, and test refusal	Carnes argued officer lacked probable cause/reasonable ground (citing similar precedents)	Court held reasonable ground existed; ALS overruled below was properly overruled and suspension upheld
Whether "reasonable ground" equals "probable cause"	State treated standard as effectively probable cause for purposes of suspension	Carnes asserted probable-cause standard not met; argued cases like Phoenix and Ruberg require more	Court noted ambiguity in law but assumed probable-cause standard for analysis and found it satisfied

Drape v. United States, 358 U.S. 307 (U.S. 1959) (equates “reasonable grounds” with “probable cause” in related statutory context)
Beck v. Ohio, 379 U.S. 89 (U.S. 1964) (officer may consider prior arrests/similar conduct in probable-cause analysis)
Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (calls for de novo review of objective legal questions from facts found)
State v. Homan, 89 Ohio St.3d 421 (Ohio 2000) (defines probable cause for OVI arrests based on trustworthy facts creating belief of impairment)
State v. Moore, 90 Ohio St.3d 47 (Ohio 2000) (probable cause as reasonable ground for belief of guilt in search/seizure context)
City of Westerville v. Cunningham, 15 Ohio St.2d 121 (Ohio 1968) (officer may consider refusal to submit to chemical testing when inferring consciousness of guilt)
State v. Craig, 110 Ohio St.3d 306 (Ohio 2006) (officer's knowledge of prior arrests is relevant to probable-cause determination)