State v. Huffman
2017 Ohio 7007
| Ohio Ct. App. | 2017Background
- At 2:25 a.m. on March 20, 2016, Abraham Huffman was stopped and later charged with OVI (R.C. 4511.19) and a marked-lanes violation (R.C. 4511.33).
- Officer testified he observed Huffman make a wide left turn, overcorrect, and cross the centerline twice (both front and rear tires over the line), and that oncoming traffic swerved to avoid Huffman.
- Dash‑cam footage was admitted and, according to the appellate court, does not show Huffman crossing the centerline or oncoming traffic swerving.
- Huffman moved to suppress evidence from the traffic stop; trial court denied the motion and Huffman pled no contest; he was convicted on the OVI count and appealed.
- The Sixth District reviewed deference to the trial court’s factual findings but independently reviewed legal application; it concluded the dash‑cam undermined the officer’s testimony and that there was not competent, credible evidence of a marked‑lanes violation to justify the stop.
- Judgment: the Sixth District reversed the trial court’s denial of the suppression motion and remanded; costs on appeal taxed to the state.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officer had reasonable, articulable suspicion to stop Huffman for a marked‑lanes violation under R.C. 4511.33 | Officer/state: testimony that Huffman crossed the centerline twice, based on officer’s observations and experience | Huffman: dash‑cam footage shows no crossing of the centerline and no oncoming vehicle swerving; thus no lawful basis for the stop | Court: Stop was not supported; dash‑cam contradicted officer’s testimony and there was not competent, credible evidence of a marked‑lanes violation; suppression warranted |
Key Cases Cited
- State v. Burnside, 100 Ohio St.3d 152 (Ohio 2003) (standard for appellate review of suppression rulings)
- State v. Codeluppi, 139 Ohio St.3d 165 (Ohio 2014) (trial court as factfinder on suppression; credibility determinations)
- State v. Mills, 62 Ohio St.3d 357 (Ohio 1992) (trial court’s role in resolving factual disputes)
- State v. Durnwald, 163 Ohio App.3d 361 (6th Dist. 2005) (accept factual findings supported by competent, credible evidence)
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (officer needs reasonable, articulable suspicion to stop a vehicle)
- State v. Marcum, 993 N.E.2d 1289 (Ohio 2013) (discussion of marked‑lanes violation standards)