State v. Littlefield
2013 Ohio 481
Ohio Ct. App.2013Background
- Trooper observed Littlefield weaving and multiple marked lane violations on SR 159 in snow-covered conditions.
- Trooper stopped Littlefield after following for about ½ to 1 mile and noting lane-line violations.
- Littlefield was asked to perform field sobriety tests and was arrested for DUI.
- At the Ross County Law Enforcement Complex, Littlefield provided a breath sample on the Intoxilyzer 8000, yielding .117.
- Defense moved to suppress both the stop evidence and the breath test results, arguing lack of reasonable suspicion and improper DOH-compliance.
- Trial court denied both suppression motions; Littlefield pled no contest to the DUI offense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there probable cause to stop? | Littlefield argues no reasonable suspicion supported the stop. | Littlefield argues the video shows obscured markings and no traffic violation. | Stop supported by reasonable suspicion; overruled. |
| Was the breath test properly admissible despite model identification issues? | Littlefield contends failure to identify OH-2 vs OH-5 undermines foundation. | State showed substantial compliance with DOH rules; documents identify instrument and calibration. | Breath test admissible; overruled. |
Key Cases Cited
- State v. Ward, 15 Ohio St.3d 355 (1984) (calibration logs admissible; routine maintenance records allowed)
- State v. Burnside, 100 Ohio St.3d 152 (2003) (substantial compliance standard for breath tests)
- State v. Wasmer, 1994 WL 90400 (1994) (suppression standards for DOH compliance (cited for doctrine))
- State v. Plummer, 490 N.E.2d 902 (1986) (substantial compliance and prejudice shift framework)
- State v. Hurst, 2009-Ohio-3127 (2009) (requires substantial compliance for admissibility of breath-test results)
- State v. Mays, 2008-Ohio-4539 (2008) (reasonable suspicion standard for traffic stops under Terry/Ohio law)