State v. Little, 2020 Ohio 4097

At ~1:00 A.M. on July 13, 2019, Officer Christopher Lemke observed Michael Little drive a white SUV, make a right turn into the eastbound lane, and stop in the middle of the roadway.
Officer Lemke turned his cruiser; as he did so the SUV accelerated away at a high rate of speed.
Officer Lemke followed and observed the SUV approach a stop sign, ‘‘slow down and hit the brakes’’ then roll through the intersection without coming to a full stop.
Officer Lemke activated lights, initiated a traffic stop; Little exited, fled on foot, and was apprehended. Officer Lemke observed signs of impairment.
Little was indicted for OVI, moved to suppress the stop as unlawful; the trial court denied the motion. Little pleaded no contest to one OVI count and appealed the denial of the suppression motion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Little)	Held
Whether the traffic stop was lawful based on observed failure to stop at the stop sign	Officer had an objectively reasonable justification: he witnessed Little roll through the stop sign, a traffic violation, giving authority to stop the vehicle	Little argued the stop was unlawful because the officer lacked reasonable, articulable suspicion; video was inconclusive and did not corroborate officer’s observation	Court held the trial court reasonably credited Officer Lemke’s testimony; witnessing the stop-sign violation supplied lawful basis for the stop
Whether stopping in the roadway (impeding traffic) justified an earlier stop	State noted officer believed Little initially impeded traffic by stopping in the roadway	Little said he stopped to allow the cruiser to pass and did not impede traffic	Court did not decide this issue because the later observed stop-sign violation alone justified the stop

Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable, articulable suspicion standard for investigatory stops)
Delaware v. Prouse, 440 U.S. 648 (1979) (vehicle stops are seizures under the Fourth Amendment)
Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (officer may initiate stop after witnessing a traffic violation)
State v. Bobo, 37 Ohio St.3d 177 (1988) (defines reasonable articulable suspicion as specific, articulable facts plus rational inferences)
State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of appellate review for suppression rulings: factual findings get deference; legal conclusions reviewed de novo)
State v. Robinette, 80 Ohio St.3d 234 (1997) (Ohio Constitution offers parallel Fourth Amendment protection)
State v. Hoffman, 141 Ohio St.3d 428 (2014) (discusses state constitutional protections and related precedent)