State v. Emmons
2016 Ohio 5384
| Ohio Ct. App. | 2016Background
- State appeals suppression ruling after a seven-minute traffic stop led to seizure of drugs found on Emmons and in the car.
- Trooper Doebrich stopped Barrett for failing to stop at a marked stop line; Emmons claimed the car was hers and provided identification.
- During the stop, the trooper questioned Barrett about the wound on his hands and about an open capias while Barrett’s identity was being verified.
- Trooper Doebrich questioned Emmons about blood on her sleeve and potential drugs; Emmons admitted recent heroin use and consented to have her sleeves pulled up.
- A needle was found in Emmons’s purse after she showed it; a bag of cocaine was later found in the car.
- The trial court granted suppression, holding there was no reasonable suspicion and the stop was impermissibly prolonged; this court reverses and remands.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the seven-minute stop unreasonably prolonged? | State: stop was lawful and questioning did not measurably extend detention. | Emmons: questioning unrelated to the stop extended detention. | No; stop not unreasonably prolonged. |
| Did the totality of circumstances establish reasonable suspicion to prolong the detention? | State: totality showed ongoing drug activity. | Emmons: no additional evidence of criminal activity. | Yes; reasonable suspicion supported ongoing detention. |
Key Cases Cited
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (stops and the need for license/registration checks in traffic stops)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (detention during investigatory stops allowed if reasonable under Terry)
- Mimms, 434 U.S. 106 (U.S. 1977) (driver may be ordered from vehicle during stop)
- Rodriguez v. United States, 135 S. Ct. 1609 (U.S. 2015) (questioning may extend stop only if not measurably prolonged)
- Muehler v. Mena, 544 U.S. 93 (U.S. 2005) (police questioning lawful if it does not extend detention)
- Bostick, 501 U.S. 429 (U.S. 1991) (consensual searches and identification requests during detention)
- Caballes, 543 U.S. 405 (U.S. 2005) (stop duration limited to the purpose of the stop)
- Arvizu, 534 U.S. 266 (U.S. 2002) (totality-of-circumstances approach to reasonable suspicion)
- Batchili, 113 Ohio St.3d 403 (2007-Ohio-2204) (prolonged stop evaluated on totality, not isolated facts)
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (review of reasonable-suspicion determinations as a mixed question of law and fact)