State v. Gaffney, 2018 Ohio 4094

On Jan 23, 2017 Trooper Bayless observed Brandon Gaffney driving a rental car on I‑77; Bayless testified Gaffney sat rigid, stared straight ahead, and followed a semi at about a two‑second gap while both traveled ~70 mph.
Bayless initiated a traffic stop for following too closely; Gaffney produced a license and an expired rental agreement and was cooperative.
After a pat‑down and while Gaffney sat in the patrol car, Trooper Bayless conducted a canine exterior sniff; the dog alerted and a subsequent search produced about one ounce of heroin in the center console.
Gaffney moved to suppress the evidence; the trial court denied the motion, a jury convicted him of heroin possession, and he received a four‑year sentence.
On appeal the Fifth District reversed and remanded, holding the trooper lawfully initiated the stop (majority) but unlawfully expanded the detention into a drug investigation without reasonable, articulable suspicion; a separate concurrence would have found no probable‑cause basis for the initial traffic stop.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Gaffney)	Held
1. Was the traffic stop supported by probable cause/legitimate basis?	Trooper observed following too closely (~2‑sec gap in wet conditions) and thus lawfully stopped the car.	The gap and driving viewed on video did not amount to a violation; the stop was pretextual.	Majority: initial stop for following too closely was supportable on the facts; concurrence: no probable cause for the stop.
2. Did officer lawfully expand the stop into an investigatory detention (dog sniff/search)?	Trooper had reasonable suspicion to investigate further based on driver’s demeanor, expired rental, authorized‑driver status, and task‑force intelligence about prior narcotics involvement.	Officer lacked new, articulable facts beyond the traffic stop; ordering Gaffney out, detaining him, and deploying the dog were an unlawful expansion.	Held: detention was unlawfully expanded; dog sniff/search were unsupported by reasonable, articulable suspicion.
3. Should evidence seized after the expanded detention be suppressed?	Evidence was valid because the stop and investigation were justified.	Evidence was fruit of an illegal detention and must be suppressed.	Held: suppression warranted because the expanded detention was illegal.
4. Were cumulative evidentiary errors that deprived Gaffney of a fair trial reversible?	N/A (State argued trial was fair).	Cumulative trial errors denied a fair trial.	Moot (court reversed on suppression grounds).

Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (reasonable‑suspicion and probable‑cause determinations reviewed de novo on appeal)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (standards for investigative stops)
Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (limits on vehicle stops and checks)
United States v. Sharpe, 470 U.S. 675 (U.S. 1985) (analysis of reasonable duration of stops and officer diligence)
Dayton v. Erickson, 76 Ohio St.3d 3 (Ohio 1996) (probable cause for traffic stops based on observed traffic violation)
City of Bowling Green v. Godwin, 110 Ohio St.3d 58 (Ohio 2006) (discussion of standards applicable to traffic stops)