State v. Houston, 2013 Ohio 686

Appellant Marcos Houston was convicted in Scioto County Common Pleas Court of trafficking in drugs with a forfeiture specification, possession of drugs, and tampering with evidence.
Houston challenged a suppression ruling, arguing the seizure extended beyond a lawful parking-violation stop.
The trial court found the stop and subsequent detentions were supported by reasonable suspicion and conducted diligently.
Evidence including a canine sniff and house visit were within the permissible scope of the traffic stop under the totality of circumstances.
Houston pled no contest to the charges; the court sentenced him to consecutive prison terms totaling ten years.
The appellate court affirmed, rejecting all three assignments of error and upholding the conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether detention during the parking stop violated Fourth Amendment time limits	State contends detention was justified by reasonable suspicion	Houston argues detention exceeded necessary time	Detention was合理 under totality of circumstances
Whether counsel’s effectiveness affected suppression error and plea choices	State contends counsel acted within reasonable strategy	Houston claims ineffective assistance hindered appeal rights	No ineffective-assistance demonstrated; record supports counsel’s conduct
Whether sentencing on three allied or non-allied offenses was proper	State argues non-merger; multiple offenses with distinct elements	Houston claims plain error in sentencing multiple offenses	No plain error; offenses not allied and proper under law

Florida v. Royer, 460 U.S. 491 (1983) (detention during traffic stop must be limited to stop purpose)
United States v. Place, 462 U.S. 696 (1983) (exterior canine sniff not a search if during stop execution)
State v. Delfino, 22 Ohio St.3d 270 (1986) (possession of different drug groups constitutes different offenses)
State v. Chatton, 11 Ohio St.3d 59 (1984) (briefing considerations for suppression motions)