State v. Hambrick, 2012 Ohio 5139

Trooper Seabolt stopped Hambrick's vehicle for a marked lanes violation after observing the vehicle cross the right-edge line by about a foot.
Two bags of marijuana were reportedly in the vehicle per transcripts, though Hambrick was the right-front passenger and the search led to oxycodone in his possession.
The Ross County Grand Jury indicted Hambrick on aggravated drug possession after the July 2009 stop; he initially pled not guilty but later entered a no contest plea.
Hambrick was convicted and sentenced to two years of community control.
Appellate counsel in an Anders v. California proceeding suggested two potential assignments of error, which the court discussed but did not find meritorious.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop supported by reasonable suspicion based on a de minimis traffic violation?	Hambrick (State) argues the stop was justified by a traffic violation.	Hambrick argues the stop was improper due to lack of reasonable suspicion.	The court held the stop permissible under Fourth Amendment law.
Did the chemist report disclosure comply with R.C. 2925.51 and Crim.R. 16(K)?	State contends disclosure complied with statutory and rule requirements.	Hambrick argues there was failure or ambiguity in timely disclosure.	No error found; any possible disclosure issue was not reversible, given the record and Hambrick's no contest plea.

Dayton v. Erickson, 76 Ohio St.3d 3 (Ohio 1996) (stop based on traffic violation permissible under Fourth Amendment)
State v. Long, 127 Ohio App.3d 328 (2006) (mixed questions of law and fact; defer to trial court on credibility)
State v. Dunlap, 73 Ohio St.3d 308 (1995) (trial court as trier of fact; deference to factual findings)
State v. Fanning, 1 Ohio St.3d 3 (1982) (standard for suppression review; credibility determinations)
State v. Venham, 96 Ohio App.3d 649 (1994) (standard for independent legal review after factual findings)