State v. Johnson
2017 Ohio 8909
Ohio Ct. App.2017Background
- At 2:36 a.m., an officer observed Hampton Johnson leave a known high‑crime motel and follow at high speed; cruiser camera recorded peak speed up to 69 mph in a 35 mph zone.
- Officer observed lane violations while pursuing Johnson; when signaling, Johnson appeared to toss something from his car; he then turned and stopped.
- On approach Johnson shifted in his seat and reached toward his lap; the officer briefly spoke with him, then ran a LEADS background check revealing prior drug convictions.
- Officer returned, requested consent to search; Johnson said "sure," attempted to exit, and ultimately consented again after backup arrived; search uncovered drug paraphernalia and later cocaine.
- Trial court suppressed only post‑handcuffing statements, denied suppression of physical evidence; Johnson pleaded no contest and appealed, arguing the stop, detention, consent, and Miranda treatment were unlawful.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Johnson) | Held |
|---|---|---|---|
| Validity of traffic stop | Officer had reasonable suspicion based on observed speeding and lane violations to stop vehicle | Stop was pretextual and unsupported; officer testified stop was for lane violations | Stop upheld: speeding and lane violations (and camera footage) provided reasonable suspicion |
| Length/scope of detention | Detention was not unreasonably prolonged; consent to search occurred during traffic mission so was valid | Officer unlawfully expanded stop with unrelated questioning and prolonged detention beyond issuing ticket | Held reasonable: initial contact brief; background check and consent occurred within mission; no undue delay |
| Validity of consent to search | Consent was voluntary during lawful detention; search was within scope | Consent coerced (not free to leave), unclear scope, officer had knowledge of contraband undermining voluntariness | Consent upheld: totality of circumstances and cruiser video show voluntary consent during lawful stop |
| Miranda suppression scope | Only statements after formal arrest (handcuffing/placing in cruiser) required suppression | Johnson was in custody earlier; pre‑handcuff statements should be suppressed | Trial court correctly suppressed only post‑handcuff statements; pre‑handcuff statements not custodial |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (defines investigative stop / Terry stop)
- Whren v. United States, 517 U.S. 806 (automobile stops are seizures evaluated under reasonableness standard)
- Illinois v. Caballes, 543 U.S. 405 (limits on prolonging a traffic stop to conduct unrelated investigations)
- Rodriguez v. United States, 135 S.Ct. 1609 (traffic stop cannot be prolonged beyond mission absent reasonable suspicion)
- State v. Mays, 119 Ohio St.3d 406 (Ohio discussion of reasonable suspicion for traffic stops)
- State v. Burnside, 100 Ohio St.3d 152 (appellate review standard for motions to suppress)