State v. Horvath
2014 Ohio 641
Ohio Ct. App.2014Background
- The State appeals a Medina Municipal Court suppression grant following Horvath’s May 25, 2012 traffic stop in Hinckley Township.
- Horvath was charged with two counts of OVI and a marked lanes violation after the stop.
- Horvath moved to suppress the evidence, contending there was no lawful basis for the stop.
- The municipal court granted the suppression motion on the theory that driving on the lane line but not over it did not violate a traffic law.
- On appeal, the Ninth District reversed in part and remanded to address whether weaving or lane violations created reasonable suspicion.
- The appellate court held that the trial court must first determine whether Horvath’s driving gave rise to reasonable suspicion of driving under the influence, and remanded for that determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did weaving within a lane give reasonable suspicion of DUI? | Horvath argues no basis for stop; weaving alone not enough | State contends weaving and lane-line crossing supported stop | Remanded for trial court to determine reasonable suspicion |
Key Cases Cited
- State v. Burnside, 100 Ohio St.3d 152 (2003-Ohio-5372) (establishes the mixed question of law and fact standard for suppression; review de novo on legal conclusions)
- State v. Mills, 62 Ohio St.3d 357 (1992) (trial court findings on credibility are reviewed, with independent legal application of standards)
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable suspicion standard for stops)