State v. Lewis, 2017 Ohio 996

On April 8, 2016, Trooper Benjamin Kohli stopped Johnny Ray Lewis’s tractor-trailer on I‑75 after observing repeated marked‑lane violations and a prior report of reckless driving.
After the stop, Kohli observed slow response to his signals, slurred/mumbled speech, a slight odor of alcohol, and staggered/balance problems when Lewis exited the truck.
Kohli asked Lewis to perform field sobriety tests (walk‑and‑turn, one‑leg stand, eye checks, alphabet), during which Lewis displayed multiple standardized‑test clues of impairment and vertical nystagmus.
Lewis admitted drinking a few alcoholic beverages and taking prescription medication (later clarified as drinking at 8:00 a.m.).
Trooper Kohli arrested Lewis for OVI; Lewis moved to suppress, the trial court denied the motion, and Lewis ultimately pleaded no contest to OVI and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable, articulable suspicion to continue the stop and order field‑sobriety testing	Trooper had reasonable suspicion based on weaving, prior reckless report, slow response to lights, slurred speech, odor, and balance problems	Lewis argued there was no evidence he had consumed alcohol or drugs before tests and thus no basis to order testing	Court held reasonable suspicion existed under the totality of the circumstances and affirmed denial of suppression
Whether officer had probable cause to arrest for OVI after the tests	Trooper had probable cause based on field‑sobriety clues (six of eight on walk‑and‑turn, one‑leg‑stand failures), nystagmus, test performance, and admission of drinking/medication	Lewis argued the only drinking admission was many hours earlier (11 hours) and insufficient to support probable cause	Court held the totality of circumstances (test clues, nystagmus, admissions, observations) supplied probable cause to arrest

State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of review for suppression: trial court findings of fact accepted if supported; legal conclusions reviewed de novo)
State v. Carter, 72 Ohio St.3d 545 (1995) (trial court is the trier of fact at suppression hearings and best positioned to assess credibility)
State v. Homan, 89 Ohio St.3d 421 (2000) (probable‑cause inquiry for OVI arrests uses totality of the circumstances)
State v. Bozcar, 113 Ohio St.3d 148 (2007) (clarification on Homan and statutory changes)
United States v. Arvizu, 534 U.S. 266 (2002) (reasonable suspicion/probable cause assessed under totality of the circumstances)