State v. Chambers, 2020 Ohio 1483

On March 30, 2017, OSP Lt. Joel Smith observed a vehicle on I‑77 initially driven by Eric Chambers, later driven by a different person; Smith followed and activated lights after observing the car closely following a semi.
Smith stopped the vehicle for following too closely in violation of R.C. 4511.34(A); both occupants were separated, patted down, and placed in the patrol car while identities were checked via LEADS.
A K‑9 handler arrived and Drago performed a sniff of the vehicle; the dog alerted at the rear, prompting a search that discovered methamphetamine under the passenger seat and later a bag of meth given by the driver; marijuana was found on Chambers.
Chambers moved to suppress, arguing the stop lacked probable cause and that the detention was unconstitutionally prolonged for the canine sniff; the trial court denied the motion.
Chambers pleaded no contest to aggravated possession of methamphetamine and appealed the denial of the suppression motion; the appellate court affirmed the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for traffic stop	Smith had probable cause: vehicle followed a semi less than a car length in violation of R.C. 4511.34(A)	Video does not show a traffic violation; stop was unjustified	Stop lawful — probable cause existed based on following too closely
Prolongation of stop for canine sniff	Dog walked around contemporaneously with identity checks; arrival and sniff occurred within reasonable time	Stop was extended to permit a dog sniff absent reasonable suspicion	No unconstitutional prolongation — sniff occurred during ordinary, diligent tasks and within the time to effectuate the stop

Whren v. United States, 517 U.S. 806 (U.S. 1996) (probable cause to believe a traffic violation occurred justifies a stop)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (investigative stops require reasonable, articulable suspicion)
Illinois v. Caballes, 543 U.S. 405 (U.S. 2005) (a dog sniff during a lawful traffic stop is not a search if it does not prolong the stop)
Rodriguez v. United States, 575 U.S. 348 (U.S. 2015) (an officer may not extend a traffic stop to conduct a dog sniff absent reasonable suspicion)
United States v. Place, 462 U.S. 696 (U.S. 1983) (canine sniff is a limited intrusion distinct from a full search)
Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (stopping a vehicle constitutes a Fourth Amendment seizure)
Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (exclusionary rule applies to state prosecutions)
State v. Batchili, 113 Ohio St.3d 403 (Ohio 2007) (duration of stop evaluated under totality and officer diligence; routine checks permitted)