State v. Hochstetler
2016 Ohio 8389
| Ohio Ct. App. | 2016Background
- On May 15, 2015 at ~10:09 p.m., Trooper Justin Ross observed a van weaving and crossing completely into the southbound lane on State Route 241; he stopped the vehicle for a lane violation described as "erratic" driving.
- Driver was Steven Hochstetler; Trooper observed bloodshot, glassy eyes and found Hochstetler's explanation for travel "odd."
- Trooper ordered Hochstetler out of the van and administered field sobriety tests; Hochstetler was arrested and submitted to breath and urine tests.
- Breath test showed no alcohol; urine test later showed presence of a marijuana metabolite. Hochstetler was charged with OVI (alcohol), lane violation, and OVI (marijuana metabolite); he pleaded no contest to the metabolite OVI and appealed the denial of his suppression motion.
- Hochstetler moved to suppress evidence arguing Trooper Ross lacked reasonable, articulable suspicion to detain him for field sobriety testing; the trial court denied the motion and this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the detention for field sobriety testing supported by reasonable, articulable suspicion? | State: Trooper had reasonable suspicion based on erratic driving, late-night stop, and bloodshot/glassy eyes. | Hochstetler: Trooper lacked specific facts to suspect impairment — he denied drinking, was cooperative, not slurring, no coordination problems, no strong odor in the van. | Court: Yes. Totality of circumstances (marked lane violation crossing into oncoming lane, time/day, and bloodshot/glassy eyes) gave reasonable suspicion to administer tests. |
Key Cases Cited
- State v. Burnside, 100 Ohio St.3d 152 (Ohio 2003) (standard for appellate review of suppression motions — trial court factual findings afforded deference, legal conclusions reviewed de novo)
- State v. Mills, 62 Ohio St.3d 357 (Ohio 1992) (trial court as factfinder for suppression hearings)
- State v. McNamara, 124 Ohio App.3d 706 (Ohio Ct. App.) (appellate review standard for suppression rulings)
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (reasonable-suspicion and probable-cause determinations reviewed de novo)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (articulable facts required to support a seizure)
- United States v. Cortez, 449 U.S. 411 (U.S. 1981) (reasonable suspicion judged by the totality of the circumstances)
- State v. Evans, 127 Ohio App.3d 56 (Ohio Ct. App.) (no single factor is dispositive in impairment/suspicion analysis)