State v. Hope, 2019 Ohio 3719

Trooper stopped a vehicle for speeding after recording speeds up to 78 mph.
When the passenger rolled down the window, the trooper smelled raw marijuana; he performed field sobriety tests on driver Taurion Hope that showed signs consistent with recent marijuana use (green haze on tongue, raised taste buds) though not appreciable impairment.
The trooper decided within nine minutes to search the car, called for backup, and began the search about 20 minutes after the stop; backup arrived to assist for officer safety.
Search uncovered marijuana debris and multiple credit cards throughout the vehicle and 13 cards on Hope; some cards were later determined to be stolen.
Hope was indicted for receiving stolen property, filed a motion to suppress (partially denied), pled no contest, was convicted and sentenced to nine months; he appealed the partial denial of the suppression motion and his sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop and subsequent 20-minute detention/search violated the Fourth Amendment	State: Trooper had valid traffic-stop basis and reasonable suspicion/probable cause to investigate drug activity (odor of marijuana, physical indicators); waiting for backup was reasonable	Hope: The continued detention and search exceeded the scope of the traffic stop and lacked reasonable, articulable suspicion of additional criminal activity	Court overruled suppression claim; stop valid at inception, indicators justified continued detention and search, and waiting for backup did not make the delay unreasonable
Whether Hope's nine‑month prison sentence for a fifth‑degree felony was lawful	State: Trial court reviewed the presentence report and imposed a sentence within the statutory range	Hope: Sentence unlawful because trial court did not state it considered R.C. 2929.11/2929.12 principles and factors	Court found the sentence contrary to law for failing to show consideration of statutory sentencing principles/factors and reversed for resentencing

United States v. Hensley, 469 U.S. 221 (U.S. 1985) (Fourth Amendment protects against unreasonable searches and seizures during stops)
State v. Robinette, 80 Ohio St.3d 234 (Ohio 1997) (traffic-stop may be extended only with reasonable, articulable suspicion of additional criminal activity)
Bowling Green v. Godwin, 110 Ohio St.3d 58 (Ohio 2006) (probable cause for vehicle search depends on circumstances known to the officer at the time)
State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (standard of appellate review for felony sentences under R.C. 2953.08(G)(2))
State v. McGowan, 147 Ohio St.3d 166 (Ohio 2016) (clarifies when an appellate court may modify or vacate a felony sentence)