State v. Hale, 2024 Ohio 4866

Law enforcement observed Terrance Cunningham, a suspected drug trafficker, driving a minivan despite having a suspended license, and planned to stop the vehicle.
When Detective Martens arrived at the convenience store parking lot, the minivan was already parked, Cunningham and the passenger, Katrina Hale, were outside the vehicle; Hale had returned briefly to the minivan before attempting to go back into the store.
Martens questioned Cunningham and Hale, ultimately detaining both; Hale was asked for identification, appeared nervous, and was asked to sit on the bumper of the patrol car with her two purses.
During questioning, Hale admitted knowing Cunningham’s license was suspended and asked him to drive her due to illness; Martens searched her purses, finding methamphetamines, and arrested her.
Hale was indicted on drug charges and firearm offenses; she moved to suppress the evidence, arguing her detention and the search of her purses violated the Fourth Amendment; the trial court suppressed the evidence, but the appellate court reversed.
The Ohio Supreme Court reviewed whether the officer’s seizure and search of Hale and her purses violated the Fourth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the detention of a passenger who has exited a parked car during a stop violates the Fourth Amendment	Hale: Detention was unlawful because she was not in the vehicle during the stop; lacked reasonable suspicion.	State: Detention was lawful due to reasonable suspicion of criminal activity and Hale’s connection to the car and possible criminal conduct.	Detention was reasonable; Fourth Amendment not violated.
Whether evidence found in purses should be suppressed as fruit of an unlawful stop	Hale: Any evidence from the purses is inadmissible as it stems from the unconstitutional stop.	State: The initial stop and subsequent detention were lawful; thus, evidence is admissible.	Evidence not suppressed, as the stop was valid.
Validity of treating this as a traffic/investigatory stop	Hale: This was not a traffic stop since the vehicle was parked and she had exited.	State: Investigatory stop was justified given totality of circumstances and Hale’s involvement.	Nature of stop immaterial; question is reasonable suspicion, which existed.
Whether the officer had reasonable suspicion to detain Hale specifically	Hale: No criminal activity reasonably suspected involving her at the time of detention.	State: Reasonable suspicion developed based on association with car, actions, and statements made.	Reasonable suspicion existed to justify detention.

United States v. Mendenhall, 446 U.S. 544 (standard for what constitutes a seizure under the Fourth Amendment)
United States v. Cortez, 449 U.S. 411 (investigatory stop requires particularized, objective basis for suspicion)
Terry v. Ohio, 392 U.S. 1 (establishes the reasonable suspicion standard for stopping and detaining individuals)
Maryland v. Wilson, 519 U.S. 408 (officers may order vehicle passengers out during traffic stops for safety)
Brendlin v. California, 551 U.S. 249 (passenger as seized during traffic stop for Fourth Amendment purposes)
Arizona v. Gant, 556 U.S. 332 (limits search of vehicle incident to arrest without separate probable cause)