State v. Goss
2017 Ohio 162
| Ohio Ct. App. | 2017Background
- Garrett S. Goss was stopped March 26, 2016 after an officer observed his pickup stop with its engine compartment beyond the stop line and the rear wheels behind it; officer said the driver’s door was on the stop bar.
- Officer initiated stop for an Ashland stop-line ordinance violation (A.C.O. § 331.19(a)); additional charges (OVI, possession of marijuana, paraphernalia) followed.
- Goss moved to suppress evidence from the stop; trial court denied the motion after a hearing and found some of Goss’s testimony not credible.
- Goss pleaded no contest to the charged offenses and appealed solely arguing the trial court erred in denying the suppression motion.
- Majority held the stop was supported by reasonable, articulable suspicion under Ohio precedent and affirmed; one judge dissented, contending the stop was not supported because the ordinance’s word “at” is ambiguous and should not be read to criminalize a vehicle partially over the line.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officer had reasonable, articulable suspicion to stop for a stop-line violation | Officer observed vehicle straddling the stop line (engine in crosswalk; driver’s door on stop bar) supporting a stop under A.C.O. § 331.19(a) | Goss argued the ordinance does not require a vehicle to be entirely before the stop line; stopping with part of vehicle over the line does not necessarily violate the ordinance | Court held the facts provided reasonable articulable suspicion to stop; affirmed denial of suppression |
| Proper interpretation of “stop at a clearly marked stop line” | N/A (State relied on officer’s reasonable suspicion under its view of ordinance) | Goss relied on cases (and dissent) interpreting “at” more permissively, arguing drivers need not avoid any contact with the line | Majority declined to adopt a single textual rule; found facts here supported suspicion. Dissent would adopt a broader reading (vehicle need not be fully before the line) |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (1996) (reasonable-suspicion and probable-cause determinations reviewed de novo on appeal)
- State v. Mays, 119 Ohio St.3d 406 (2008) (officer’s stop valid if prompted by reasonable, articulable suspicion)
- State v. Fanning, 1 Ohio St.3d 19 (1982) (standards for appellate review of suppression rulings)