State v. Hatfield
2011 Ohio 597
Ohio Ct. App.2011Background
- Appellee Hatfield was stopped in Morrow County after a Trooper observed him driving left of center on Township Road 49, a 19-foot-wide, blacktop road with no centerline or fog lines.
- The stop occurred at night in dark, wet, and icy conditions with few other vehicles present; the trooper smelled alcohol, noted glassy eyes, and heard slurred speech.
- Hatfield admitted driving down the center to avoid potholes and deer, a fact Trooper Johnson used to justify the stop.
- Hatfield performed field sobriety tests, and the trooper administered the HGN test, which yielded six of six clues indicating intoxication.
- Hatfield waived Miranda rights, admitted consuming four to five beers with the last within about 20 minutes of the stop, and was arrested for driving left of center and OVI.
- The trial court granted Hatfield’s motion to suppress, relying in part on ODOT’s Location and Design Manual to conclude the road width prevented a lawful stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there reasonable suspicion to stop Hatfield for driving left of center? | State: yes, DR left of center plus odor, tests support suspicion. | Hatfield: no, road width and conditions negate suspicion; no constitutionally justified stop. | Yes, there was reasonable suspicion to stop. |
| Did the trial court err in taking judicial notice of the ODOT Location and Design Manual to assess road width? | State: manual is relevant to width considerations in evaluating stop. | Hatfield: manual improperly relied upon without testimony about local road conditions. | Judicial notice of the manual was improper; but record supported stop on other grounds. |
Key Cases Cited
- Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (investigative stop must be temporary and minimally intrusive)
- United States v. Ferguson, 8 F.3d 385 (6th Cir. 1993) (objective assessment of officer's actions at time of stop)
- Florida v. Royer, 460 U.S. 491 (1983) (probable cause not required for every stop; limits of searches)
- State v. Long, 127 Ohio App.3d 328 (1998) (mixed question of law and fact in suppression review)
- State v. Williams, 86 Ohio App.3d 37 (1993) (proper legal standards applied to suppression findings)
- State v. Metcalf, 111 Ohio App.3d 142 (1996) (credibility and factual findings respected when supported by evidence)
- State v. Fanning, 1 Ohio St.3d 19 (1982) (weight of evidence standard in suppression challenges)
- State v. Klein, 73 Ohio App.3d 486 (1991) (appellate review of suppression decisions)