State v. Haynes
2015 Ohio 3432
Ohio Ct. App.2015Background
- Police had long received complaints and made numerous arrests for drug activity in the Deveroes store parking lot in Camp Washington.
- Undercover Sergeant Hudson observed Haynes park in a white car with a passenger (Jonas Whorton); the passenger approached a red car, exchanged an item for currency, then returned to Haynes’s car.
- Hudson broadcasted a description of the apparent drug transaction; Officer Mack stopped Haynes’s car about a tenth of a mile away.
- Officer Mack saw a small digital scale with residue in the car’s center console, questioned Haynes, and arrested him; during a pat-down he felt a large object in Haynes’s pants that Haynes then removed and dropped — it was heroin.
- Haynes testified he and his passenger had merely shopped, acknowledged the scale in the console, and claimed the officer coerced him to remove the item from his pants.
- The trial court denied Haynes’s motion to suppress; he pleaded no contest to trafficking and possession of heroin and was sentenced to two years. He appealed, arguing the stop and search were unlawful.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of the traffic stop/arrest | Stop/arrest justified: undercover observed apparent drug sale; radio broadcast gave probable cause | Stop lacked reasonable suspicion/probable cause; suppression required | Court: Undercover broadcast plus scale with residue supplied probable cause; stop/arrest lawful |
| Lawfulness/scope of pat-down/search | Search incident to lawful arrest permits full search for weapons and evidence | Pat-down exceeded Terry authority; no reasonable suspicion he was armed | Court: Search was incident to arrest (not limited to Terry); full search allowed under Robinson |
| Length/detention after passenger’s arrest | Continued detention/search of Haynes valid because officers had probable cause against him | Detention exceeded Terry scope once passenger was arrested; lacked suspicion for Haynes | Court: Because probable cause supported Haynes’s arrest, continued detention and search were lawful |
Key Cases Cited
- Delaware v. Prouse, 440 U.S. 648 (stopping a vehicle requires reasonable, articulable suspicion)
- Navarette v. California, 134 S. Ct. 1683 (radio reports can support reasonable suspicion/probable cause)
- Illinois v. Gates, 462 U.S. 213 (probable cause requires a probability of criminal activity)
- Chimel v. California, 395 U.S. 752 (search incident to arrest scope principles)
- United States v. Robinson, 414 U.S. 218 (full search of arrestee lawful incident to arrest)
- Terry v. Ohio, 392 U.S. 1 (stop-and-frisk/protective pat-down standard)
- Minnesota v. Dickerson, 508 U.S. 366 (limits on protective searches for weapons)