State v. Kuhn, 2021 Ohio 2165

Around 2:30 A.M., Sgt. Joe Rose followed Robert Kuhn northbound on Route 94 after Kuhn turned from State Street onto Route 94.
Sgt. Rose observed two traffic violations: Kuhn’s left tires crossed over a double-yellow line (marked-lanes violation) near Mill Street, and later Kuhn changed lanes in/through an intersection without signaling.
Sgt. Rose stopped Kuhn, conducted field sobriety tests, arrested him for OVI, and a breath test showed a .081 BAC; Kuhn was charged under R.C. 4511.19(A)(1)(a) and (d).
Kuhn moved to suppress, arguing the traffic stop lacked reasonable, articulable suspicion because he was unfamiliar with the curved intersection and there were not continuous lane markings or arrows.
The municipal court denied suppression based on Sgt. Rose’s testimony and dash-cam video corroboration; Kuhn pleaded no contest and was convicted. He appealed the denial of the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was supported by reasonable suspicion	Kuhn: unfamiliar road and lack of continuous markings made his lane position and un-signaled movement de minimis and not suspicious	State: officer observed two traffic violations (crossing double-yellow line; changing lanes without signal); any traffic violation supplies reasonable suspicion	Court: Stop was valid; observed violations provided reasonable, articulable suspicion

State v. Burnside, 100 Ohio St.3d 152 (2003) (standard for appellate review of suppression—accept trial court’s factual findings if supported, independently review legal conclusion)
Whren v. United States, 517 U.S. 806 (1996) (vehicle stop is a seizure; objective traffic violation suffices regardless of officer’s subjective intent)
Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (observance of any traffic law violation provides reasonable suspicion for investigatory stop)
State v. Mays, 119 Ohio St.3d 406 (2008) (drifting over lane markings supports constitutionally valid traffic stop)