State v. Hahn, 2016 Ohio 7585

At ~12:55 a.m., Officer Rafferty followed a white Chevrolet Cobalt leaving a bar after observing it drive outside its marked lane multiple times and attempt an illegal left turn into a Walmart lot.
Rafferty activated his cruiser lights and stopped the vehicle; he observed glassy, bloodshot eyes, smelled alcohol, and noted slow/delayed actions by the driver, Richard Hahn.
Hahn refused field sobriety tests and refused chemical testing at the station; he was arrested and charged with OVI, seatbelt and lane violations.
Hahn moved to suppress evidence, arguing the traffic stop lacked reasonable articulable suspicion because cruiser video did not show the alleged violations.
The trial court credited Rafferty’s testimony (including that the cruiser camera only saves video starting when lights are activated, plus one minute prior) and denied suppression.
Hahn pleaded no contest to one OVI count, appealed the denial of suppression, and the appellate court affirmed the denial and judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable suspicion to stop the vehicle	Officer observed marked-lane violations and attempted illegal left turn, giving reasonable suspicion for an investigatory stop	Hahn argued the cruiser video did not show any violations and therefore Rafferty lacked reasonable suspicion	Court held Rafferty had reasonable articulable suspicion; suppression denial affirmed
Whether trial court’s factual findings about lane violations and illegal turn were against the manifest weight of the evidence	Testimony about multiple lane departures and illegal turn supported the stop	Video footage contradicted officer; camera recording began only when lights activated, omitting earlier conduct	Court deferred to trial court’s credibility findings and found facts supported by competent, credible evidence

Terry v. Ohio, 392 U.S. 1 (established standard for investigative stops based on reasonable suspicion)
Delaware v. Prouse, 440 U.S. 648 (vehicle stops and constitutional limits on seizures)
United States v. Cortez, 449 U.S. 411 (totality of the circumstances test for reasonable suspicion)
Whren v. United States, 517 U.S. 806 (any traffic-law violation provides reasonable suspicion for stop)
State v. Burnside, 100 Ohio St.3d 152 (standard of review for suppression: trial court as factfinder; appellate court reviews legal conclusions de novo)
State v. Mills, 62 Ohio St.3d 357 (credibility determinations at suppression hearing are for the trial court)
Dayton v. Erickson, 76 Ohio St.3d 3 (traffic-law violation supports stop)
State v. Wilhelm, 81 Ohio St.3d 444 (traffic violations as basis for stops)
State v. McNamara, 124 Ohio App.3d 706 (appellate review principles cited for suppression issues)
State v. Epling, 105 Ohio App.3d 663 (reasonable suspicion is less than probable cause; supports investigatory stops)