State v. Leder
2019 Ohio 2866
Ohio Ct. App.2019Background
- At 4:03 a.m. on May 28, 2018, Trooper Haggerty observed Bradley Leder driving unusually slowly on I‑275 and followed him.
- While approaching the exit to SR‑125, the trooper testified Leder changed lanes and activated his turn signal only after he had already moved toward the exit (alleged violation of R.C. 4511.39(A)).
- The trooper also testified Leder ‘‘rolled through’’ a red light on the ramp while again activating his right turn signal late, and briefly touched a dotted lane line (alleged R.C. 4511.33(A)(1) marked‑lane violation).
- The trooper stopped Leder, administered a breath test (result .150), and charged him with OVI and two turn‑signal violations; Leder moved to suppress the stop.
- The trial court viewed the cruiser‑camera video, found the trooper’s testimony credible, denied the suppression motion, and Leder pleaded no contest to OVI.
- The court of appeals affirmed, holding the trooper had reasonable suspicion to initiate an investigative traffic stop; officer mistakes of law or fact that are objectively reasonable can still justify a stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trooper had reasonable, articulable suspicion to stop Leder for traffic violations | Trooper had reasonable suspicion because he observed late/insufficient use of turn signals and a marked‑lane touch | Leder argued the trooper’s testimony and cruiser video did not credibly show violations and thus lacked reasonable suspicion | Court held trooper had reasonable suspicion; testimony and video provided competent, credible evidence and reasonable mistakes are permissible |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (establishes standard for investigative (Terry) stops)
- Heien v. North Carolina, 574 U.S. 54 (an objectively reasonable mistake of law can support reasonable suspicion)
- United States v. Sokolow, 490 U.S. 1 (totality of circumstances test for reasonable suspicion)
- State v. Andrews, 57 Ohio St.3d 86 (reasonable‑suspicion standard viewed through officer’s perspective)
- State v. Mays, 119 Ohio St.3d 406 (probable cause implies reasonable and articulable suspicion)
- Dayton v. Erickson, 76 Ohio St.3d 3 (officer’s ulterior motive does not invalidate a lawful stop)