State v. Hall
2017 Ohio 2682
| Ohio Ct. App. | 2017Background
- At 1:31 a.m. officer Towe stopped Hall for running two stop signs; Hall and a front-seat passenger had no ID on them.
- Towe asked for names/DOBs; he misheard Hall’s first name and dispatcher had trouble confirming identity, so Towe obtained Hall’s SSN and confirmed a valid license by about 1:42–1:43 a.m.
- While confirming identity, Towe requested a K-9 sniff; after identity was confirmed he told Hall the dog was en route and spoke with another officer who suggested he “stall.”
- After 1:43 a.m. Towe did nothing to process the citation for approximately eight minutes while waiting for the canine; the K-9 arrived ~1:52 a.m., sniff began ~1:54 a.m., and the dog alerted ~1:55 a.m.
- Evidence of methamphetamine precursors was found after the positive canine alert; Hall moved to suppress arguing the stop was unreasonably extended and the trial court granted the motion.
- The State appealed, arguing the identity delay was reasonable and the overall time remained within the officer’s normal citation-processing window.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Hall) | Held |
|---|---|---|---|
| Whether the traffic stop was unreasonably prolonged by a K-9 sniff | Delay attributable to a reasonable identity-confirmation; overall time fell within officer’s usual 12–13 min citation time | Officer stalled for a K-9; eight-minute period of inaction unlawfully extended the stop | Court affirmed suppression: officer unreasonably prolonged the stop to await K-9 |
| Whether misidentification delay may be charged to officer | Misunderstanding was reasonable and partly caused by Hall’s failure to carry ID, so delay was justified | Delay was not justified and cannot excuse the later waiting period | Court accepted that identity confusion was reasonable but still found subsequent eight-minute inaction dispositive |
| Whether officer acted diligently in pursuing traffic-related tasks | Officer acted diligently in confirming identity and could have been processing citation while confirming | Officer did not process citation and instead waited for K-9 on others’ suggestion | Court found lack of diligence: officer did nothing for ~8 minutes, so sniff added time to the stop |
| Whether Rodriguez allows incremental prolongation if overall duration is reasonable | Overall duration compared to similar stops can justify unrelated checks if officer diligent | Rodriguez prohibits prolonging a stop to conduct unrelated investigations without reasonable suspicion | Court applied Rodriguez: what officers in fact do matters; here sniff prolonged the stop and violated the Fourth Amendment |
Key Cases Cited
- Burnside v. State, 100 Ohio St.3d 152 (Ohio 2003) (standard of appellate review for suppression: factual findings accepted if supported, legal conclusions reviewed de novo)
- State v. Batchili, 113 Ohio St.3d 403 (Ohio 2007) (traffic stop must last only as long as necessary to issue citation or warning)
- Rodriguez v. United States, 135 S.Ct. 1609 (U.S. 2015) (officer may not prolong a stop to conduct unrelated checks, including a canine sniff, absent reasonable suspicion)
- United States v. Hill, 195 F.3d 258 (6th Cir. 1999) (processing driver’s license/registration and issuing citation are within scope of a traffic stop)