State v. Haynesworth
2019 Ohio 1986
Ohio Ct. App.2019Background
- Anonymous 911 caller reported "two men" walking in the middle of Grace Avenue trying car door handles; the recording is not in the record.
- About two minutes later, Lakewood officers stopped two men (Haynesworth and Jones) walking on a different street (Detroit Avenue); the patrol car pulled up abruptly and officers exited quickly.
- Officers demanded identification, retained IDs while running LEADS checks, handcuffed Haynesworth after dispatch confirmed an outstanding warrant, and ~30 minutes later Haynesworth disclosed a handgun in his waistband.
- Defense moved to suppress the gun; parties stipulated the court could decide based on briefs, two pages of the police report, and body-camera video (no suppression hearing transcript).
- Trial court denied suppression without factual findings; Haynesworth pled no contest, was convicted and sentenced, then appealed contending the initial stop lacked reasonable suspicion.
- The court of appeals reversed and vacated the conviction, holding the encounter was a seizure (not consensual) and the anonymous tip lacked sufficient detail or corroboration to supply reasonable suspicion for a Terry stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the encounter a consensual public encounter or a seizure? | Officers characterized it as a routine, consensual stop. | Commanding approach, abrupt stop, officers exiting car, retention of IDs and tone made a reasonable person feel not free to leave. | Seizure — not a consensual encounter. |
| Did the anonymous 911 tip provide reasonable suspicion for an investigative stop? | The anonymous call justified investigation; Navarette supports reliability of some 911 tips. | Tip lacked descriptive details or predictive information and was not corroborated; J.L. controls. | Tip insufficient; no reasonable, articulable suspicion for a Terry stop. |
| Did the trial court need to issue essential factual findings when denying suppression? | No duty because parties waived a hearing and defense withdrew a later motion for findings. | (Argued need for findings to review suppression properly.) | No duty to issue findings where defendant withdrew motion; appellate review proceeds on stipulated record. |
| Was the gun seizure admissible under Terry/its exceptions? | Seizure followed lawful stop and discovery was valid. | Because the stop was unlawful, the subsequent discovery was fruit of an unconstitutional seizure. | Suppression warranted; conviction vacated. |
Key Cases Cited
- State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of appellate review for suppression rulings)
- Katz v. United States, 389 U.S. 347 (1967) (warrantless searches are presumptively unreasonable)
- Florida v. Bostick, 501 U.S. 429 (1991) (consensual encounters do not implicate the Fourth Amendment)
- United States v. Mendenhall, 446 U.S. 544 (1980) (objective test for seizure: would a reasonable person feel free to leave)
- Terry v. Ohio, 392 U.S. 1 (1968) (investigative stop requires reasonable, articulable suspicion)
- State v. Bobo, 37 Ohio St.3d 177 (1988) (totality-of-circumstances test for stops)
- Florida v. J.L., 529 U.S. 266 (2000) (anonymous tip lacking predictive detail insufficient to justify stop-and-frisk)
- Navarette v. California, 572 U.S. 393 (2014) (certain 911 reports may supply reasonable suspicion when the tip has indicia of reliability)
- Maumee v. Weisner, 87 Ohio St.3d 295 (1999) (categories and reliability differences for informants)