State v. Crayton
2017 Ohio 705
| Ohio Ct. App. | 2017Background
- On Dec. 6, 2014, police responded to a fight at the Thirsty Bird bar; appellant Frank Crayton was found in the parking lot badly injured and intoxicated, bleeding from his head and with facial swelling.
- Lt. Blaney called for an ambulance, detained Crayton to render aid, and performed a frisk for weapons citing the violent scene, the bar’s reputation for people being armed, and knowledge of Crayton’s prior narcotics activity and occasional armed status.
- During the protective pat-down, Blaney felt and seized a bag of marijuana from Crayton’s front pocket; continuing the frisk, he recovered a second bag containing brown powder that he and subsequent BCI testing identified as heroin (1.38 g).
- Crayton was arrested, indicted for trafficking and possession of heroin (both fourth-degree felonies) and a forfeiture specification for $1,504 in cash; he filed a motion to suppress the evidence, arguing the frisk/search and arrest were unlawful.
- The trial court denied suppression (finding exigency/community care and reasonable suspicion to frisk); a jury convicted Crayton of trafficking and possession; trial court merged counts, sentenced him to 18 months, and ordered forfeiture.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the warrantless stop/detention lawful? | Police: community caretaking/emergency aid and Terry-level reasonable suspicion justified brief detention. | Crayton: detention was not justified because injuries were not life-threatening and no exigency existed. | Court: Detention lawful under emergency-aid/community-caretaking and totality supported reasonable suspicion. |
| Was the frisk for weapons justified? | Police: violent scene, bar known for weapons, appellant’s evasive behavior and prior reputation supported frisk. | Crayton: no reasonable, articulable suspicion he was armed; frisk lacked basis beyond calling an ambulance. | Court: Frisk justified—specific reasonable inferences supported a belief Crayton might be armed. |
| Was seizure of contraband during pat-down lawful (plain-feel) and did it provide probable cause to arrest? | Police: during lawful pat-down, officer felt object whose criminal character was immediately apparent and seized it; marijuana and heroin justified arrest/search-incident. | Crayton: officer lacked probable cause from a misdemeanor marijuana amount to arrest and continue search. | Court: Seizures lawful under plain-feel; criminal character was immediately apparent, supporting arrest and further seizure. |
| Were the convictions supported by the manifest weight of the evidence (possession and trafficking)? | State: Blaney’s testimony, BCI confirmation of heroin, quantity and $1,504 in mostly $20s supported trafficking inference. | Crayton: denied heroin possession and offered alternative source for cash (casino winnings). | Court: Jury reasonably credited state witnesses; weight of evidence supports possession and trafficking convictions. |
Key Cases Cited
- Katz v. United States, 389 U.S. 347 (establishes general Fourth Amendment search-and-seizure principles)
- Terry v. Ohio, 392 U.S. 1 (authorizes brief investigatory stops and protective frisks based on reasonable suspicion)
- State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression hearings)
- Maumee v. Weisner, 87 Ohio St.3d 295 (totality-of-the-circumstances test for reasonable suspicion)
- State v. Bobo, 37 Ohio St.3d 177 (officer may frisk during investigative stop if reasonable suspicion individual is armed)
- State v. Dunn, 131 Ohio St.3d 325 (community-caretaking/emergency-aid exception permits stops to render aid)
- State v. Thompkins, 78 Ohio St.3d 380 (standard for reviewing manifest-weight-of-the-evidence claims)