State v. Hampton, 2022 Ohio 1380

Officer from Regional Narcotics Unit observed Hampton driving a silver Dodge Charger with heavy window tint and Tennessee (rental) plates; officer could not stop for tint based on out-of-state plates and followed the vehicle to observe driving.
Officer alleged Hampton twice followed the car ahead too closely on southbound I-75 (estimated speed 55 mph; officer estimated 1–1.5 car lengths) and stopped the vehicle for violating R.C. 4511.34 (following too closely).
A drug-detection dog alerted; officers found controlled substances in the center console and on the rear floor; Hampton was indicted on drug offenses.
Hampton moved to suppress, arguing the traffic stop violated the Fourth Amendment; the trial court granted suppression, finding lack of probable cause or reasonable suspicion.
The court of appeals reviewed de novo the legal ruling (deferring to trial-court factual findings) and affirmed suppression, holding the stop lacked probable cause under R.C. 4511.34 after evaluating the totality of circumstances and video evidence (roads dry, daytime, good visibility, moderate traffic, and roughly two car lengths of spacing).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the traffic stop supported by probable cause or at least reasonable suspicion that Hampton violated R.C. 4511.34 (following too closely)?	Officer had probable cause: Hampton followed at ~1–1.5 car lengths at ~55 mph, violating R.C. 4511.34.	No reasonable suspicion or probable cause: video and conditions show at least ~2 car lengths and safe spacing; totality of circumstances does not show "more closely than is reasonable and prudent."	Affirmed suppression — no probable cause for R.C. 4511.34; stop unconstitutional; evidence suppressed.

Whren v. United States, 517 U.S. 806 (1996) (pretextual motive does not invalidate a traffic stop supported by probable cause)
State v. Mays, 119 Ohio St.3d 406 (2008) (investigative stop lawful on reasonable and articulable suspicion)
City of Bowling Green v. Godwin, 110 Ohio St.3d 58 (2006) (probable-cause determinations are fact-dependent and viewed objectively based on what officer knew at the time)
City of Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (probable cause for traffic stop justifies stop even if officer had ulterior motive)
State v. Woods, 117 N.E.3d 1017 (Ohio Ct. App.) (violation under R.C. 4511.34 assessed by totality of circumstances)
State v. Holmes, 139 N.E.3d 574 (Ohio Ct. App.) (one-car-length-per-10-mph is an estimation tool, not a rigid standard)
State v. George, 45 Ohio St.3d 325 (1989) (appellate deference principles for trial-court factual findings)