State v. Gurley, 54 N.E.3d 768

Trooper Lewis stopped Tya Gurley on SR-23 for following too closely and slowing below the speed limit; dashcam and witness testimony were presented at a suppression hearing.
During the stop Lewis checked Gurley’s record, recognized her from a prior stop, and called a drug dog unit; the dog passively alerted to drugs after about five minutes.
Gurley was Mirandized, placed in the patrol cruiser, questioned about contraband, and expressed confusion and asked, “Is there anybody I can call—someone, a lawyer or anything…?”
Lewis continued questioning, offered Gurley the option to go voluntarily to the patrol post to remove contraband, and Gurley ultimately admitted to having heroin concealed and voluntarily removed it at the post.
Gurley moved to suppress evidence and statements on Fourth and Fifth Amendment (Miranda) grounds; the trial court denied the motion. She pleaded no contest to trafficking and tampering and appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Gurley)	Held
Was the traffic stop lawful?	Trooper had reasonable, articulable suspicion and probable cause to stop for following too closely; dog sniff was timely.	The dashcam and Gurley’s testimony undermine Trooper’s account; no probable cause for stop.	Stop was lawful: court deferred to trial court credibility findings and found a traffic violation and reasonable suspicion.
Was the duration/expanded detention lawful?	Dog arrived ~5 minutes; expanded scope justified by license check, prior contact, and dog alert; detention reasonable.	Thirty-minute total detention and dog sniff unlawfully prolonged stop.	Duration and expansion were lawful because additional facts gave rise to reasonable suspicion and the sniff did not unconstitutionally extend the stop.
Did Gurley invoke her Miranda right to counsel?	Any request to call “a lawyer or anything” was ambiguous; not an unambiguous invocation.	Gurley asked to call an attorney and was confused; questioning should have ceased under Miranda.	Court held the statement was ambiguous; Trooper not required to stop questioning—no unequivocal invocation.
Were subsequent statements admissible after alleged invocation?	Even if ambiguous, Gurley continued to ask questions and did not clearly invoke counsel; admissible.	Statements after invocation should be suppressed.	Admissible: because no clear invocation; court did not reach whether she reinitiated questioning.

Miranda v. Arizona, 384 U.S. 436 (establishing custodial interrogation warnings)
Davis v. United States, 512 U.S. 452 (suspect must make an unambiguous request for counsel to invoke Edwards protection)
Rodriguez v. United States, 575 U.S. 348 (dog sniff that extends a traffic stop absent reasonable suspicion violates Fourth Amendment)
Edwards v. Arizona, 451 U.S. 477 (interrogation must cease after invocation of right to counsel)
Rhode Island v. Innis, 446 U.S. 291 (definition of interrogation under Miranda)
United States v. Sharpe, 470 U.S. 675 (reasonable duration of investigatory stops evaluated under totality of circumstances)
State v. Robinette, 80 Ohio St.3d 234 (officer may expand scope of stop if reasonable suspicion of additional criminal activity)
State v. Mays, 119 Ohio St.3d 406 (reasonable suspicion suffices for traffic stops)