State v. Hill
2016 Ohio 3087
Ohio Ct. App.2016Background
- Deputy John Campbell stopped Christopher Hill's car for failing to signal and running the vehicle's info after being asked for ID/registration.
- Campbell called for backup and, per department policy and prior district precedent, deployed his certified drug dog to perform a free-air sniff.
- The backup arrived within about a minute; the dog alerted to the passenger door within 5–10 minutes of the initial stop.
- Officer searched the car after the alert and found a bag of suspected marijuana on the passenger floorboard.
- Hill moved to suppress, arguing the canine sniff unlawfully extended the traffic stop; the trial court denied the motion, Hill pled no contest, was sentenced, and appealed.
- The appellate court affirmed, holding the officer acted in objectively reasonable, good-faith reliance on binding appellate precedent existing before Rodriguez.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the canine sniff unlawfully extended the traffic stop in violation of the Fourth Amendment | State: sniff occurred during ordinary traffic-stop tasks and within reasonable time; officer acted per then-binding precedent | Hill: Rodriguez requires suppression because the sniff ‘‘measurably extended’’ the stop beyond its traffic purpose and lacked separate reasonable suspicion | Court: affirmed suppression denial — officer acted in objectively reasonable good-faith reliance on binding local appellate precedent, so exclusionary rule did not apply |
Key Cases Cited
- Rodriguez v. United States, 575 U.S. 348 (2015) (holding a dog sniff during a traffic stop is lawful only if it does not measurably extend the stop)
- Florida v. Royer, 460 U.S. 491 (1983) (investigative stops must be temporary and last no longer than necessary)
- State v. Batchili, 865 N.E.2d 1282 (Ohio 2007) (time to complete computer checks and citation is part of reasonable stop duration)
- State v. Johnson, 22 N.E.3d 1061 (Ohio 2014) (evidence obtained in objectively reasonable, good-faith reliance on binding appellate precedent is not subject to exclusionary rule)
- Ornelas v. United States, 517 U.S. 690 (1996) (application of law to suppression hearing facts reviewed de novo)