State v. Hall, 70 N.E.3d 1154

Shortly before 1:30 a.m., Trooper Castellanos observed Marcus Hall make a left turn onto Fulton Drive and concluded Hall drove over the double yellow center lines; he initiated a traffic stop.
Trooper approached, smelled alcohol and marijuana from the vehicle, and observed Hall with red, watery, bloodshot eyes; one female passenger was present.
Trooper asked Hall to exit, detected alcohol odor on Hall’s person after a pat-down, and conducted standardized field sobriety tests, observing HGN, walk-and-turn, and one-leg-stand clues.
Hall was charged with OVI and related traffic/marijuana offenses; he moved to suppress evidence obtained after the stop.
The municipal court denied the suppression motion (crediting the trooper’s testimony that Hall crossed the center line) and Hall pled no contest to OVI and other counts.
On appeal, the Fifth District affirmed the stop as justified by the lane violation but held the trooper lacked reasonable suspicion to expand the encounter to require exit and field sobriety testing; evidence from the sobriety testing was suppressed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Was the initial traffic stop supported by reasonable suspicion?	The State: trooper observed Hall drive over double yellow center lines during the left turn, justifying the stop.	Hall: video did not clearly show crossing the center line; stop therefore unsupported.	Court: Stop was lawful — trooper testimony and camera limitations supported finding of lane violation.
2) Was there reasonable suspicion to detain Hall further and administer field sobriety tests?	The State: odor of alcohol and marijuana plus bloodshot eyes supplied reasonable suspicion for FSTs.	Hall: few indicia of intoxication — no slurred speech, no admission of drinking, controlled movements; odor alone insufficient.	Court: Lack of additional indicia meant no reasonable basis for removing Hall and administering FSTs; evidence from those tests must be suppressed.

Terry v. Ohio, 392 U.S. 1 (defines reasonable suspicion for investigative stops)
Ornelas v. United States, 517 U.S. 690 (reasonable suspicion and probable cause reviewed de novo)
Dayton v. Erickson, 76 Ohio St.3d 3 (traffic violation observed justifies stop)
State v. Bobo, 37 Ohio St.3d 177 (totality of circumstances for investigative stops)
State v. Burnside, 100 Ohio St.3d 152 (trial court findings in suppression hearings entitled to deference when supported by credible evidence)
State v. Mays, 119 Ohio St.3d 406 (officer’s decision to stop for traffic violation must be reasonable and articulable)
State v. Freeman, 64 Ohio St.2d 291 (totality of circumstances approach to justification for expanded detention and testing)