State v. Codeluppi
139 Ohio St. 3d 165
| Ohio | 2014Background
- Codeluppi was charged with speeding and OV I after a traffic stop in 2011, with no video of the stop or field sobriety tests.
- Only the police report was provided; it described three NHTSA-standardized tests but lacked instructions or demonstrations.
- Codeluppi moved to suppress, arguing improper administration of field sobriety tests and lack of probable cause.
- The trial court denied the motion to suppress for lack of particularity, and Codeluppi pled no contest after a pretrial conference.
- The Ninth District affirmed, holding the motion lacked specificity on key factual bases and NHTSA noncompliance.
- The Ohio Supreme Court reversed, holding that a detailed pleading was not required to trigger a suppression hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Crim.R. 47 notice sufficient without exhaustive facts? | Codeluppi provided sufficient notice of NHTSA noncompliance. | The motion lacked precise factual allegations to guide the court. | Yes; no excessive detail required. |
| What standard governs suppression motions on appeal? | Trial court factual findings should be reviewed for substantial compliance with law. | Deference to trial court’s decision applies if no hearing. | De novo review for legal questions; hearing required if Crim.R. 47 standards met. |
| Admissibility of field sobriety test results under R.C. 4511.19(D)(4)(b)? | Evidence admissible if substantial compliance with NHTSA guidelines is shown by clear and convincing evidence. | Admissibility cannot be determined without suppression hearing on compliance. | Evidence is admissible if substantial compliance is shown. |
| Should the suppression motion have been heard at a hearing? | Shindler notice requirements permit a hearing when standards are met, not a fishing expedition. | Without detailed facts, a hearing is not mandatory. | Trial court must hold a suppression hearing when minimum Crim.R. 47 standards are satisfied. |
| Scope of the Shindler notice requirement in this case? | Notice given by alleging noncompliance with NHTSA guidelines suffices. | Not enough specificity to place State on notice. | Notice was sufficient; no need for excruciating detail. |
Key Cases Cited
- State v. Shindler, 70 Ohio St.3d 54 (1994) (notice requires sufficient specificity to trigger suppression hearing)
- State v. Mills, 62 Ohio St.3d 357 (1992) (trial court as trier of fact; appellate review on factual findings)
- State v. Fanning, 1 Ohio St.3d 19 (1982) (standard for reviewing suppression findings)
- State v. Consilio, 114 Ohio St.3d 295 (2007) (de novo review for questions of law in suppression)
- State v. Burnside, 2003-Ohio-5372 (2003) (mixed question of law and fact in suppression)