State v. Hughes, 2013 Ohio 808

Hughes convicted of Possession of Drug Abuse Instruments after suppression motion denied.
Officers stopped Hughes for failing to signal; vehicle observed in high-drug area and Hughes lingered at a gas station.
Hughes ignored multiple stop signals and drove into a dumpster; he was pulled from vehicle and handcuffed.
Officer observed belt and soda can linked to heroin use in plain view; found a needle and brownish substance believed to be heroin.
Hughes gave statements after being advised of rights; trial court admitted statements after Miranda waiver.
Court upheld suppression denial; found reasonable concern for officer safety, permissible pat-down, and valid Miranda waiver.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did trial court err in denying suppression motion?	Hughes argues illegal seizure and search.	Hughes contends lack of lawful stop/paramount Miranda issue.	No error; suppression denied.

State v. Rodriguez, 2010-Ohio-1944 (12th Dist. Preble No. CA2009-09-024, 2010) (limited protective frisk justified by danger; weapons concern)
State v. Evans, 1993-Ohio-186 (Supreme Court, 67 Ohio St.3d 405) (protective search standard; legitimate safety justification)
Terry v. Ohio, 392 U.S. 1 (1968) (reasonable suspicion for pat-down to prevent harm)
Maryland v. Wilson, 519 U.S. 408 (1997) (allowing removal of detainee from vehicle during detention)
Pennsylvania v. Mimms, 434 U.S. 106 (1977) (authorized precautionary detentions during traffic stops)
State v. Strozier, 172 Ohio App.3d 780 (2007-Ohio-4575) (Quarles public-safety exception narrowly tailored)
State v. Santiago, 2002-Ohio-1114 (9th Dist.) (public-safety rationale in Quarles context)
New York v. Quarles, 467 U.S. 649 (1984) (public-safety exception to Miranda)
State v. Gumm, 73 Ohio St.3d 413 (1995) (totality of circumstances for knowing, voluntary waiver)