State v. Martin
2013 Ohio 1846
Ohio Ct. App.2013Background
- Defendant Virgil M. Martin III challenged a police stop as lacking reasonable articulable suspicion.
- Sgt. David Page observed a pickup leaving Watson's storage facility at about 1:00 a.m. and began the stop.
- The area had unfenced storage facilities and no business activity open at that hour.
- There had been multiple recent storage-facility break-ins in the area.
- The trial court denied suppression; the appellate court reviews de novo the constitutional question.
- The court held the stop valid under Terry and related Ohio standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was supported by reasonable suspicion | Martin argues no reasonable suspicion | Page had articulable facts showing risk of criminal activity | Yes; stop upheld; reasonable suspicion found |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (established reasonable suspicion standard for brief stops)
- State v. Carter, 69 Ohio St.3d 57 (1994) (standing to challenge seizure by passenger)
- State v. Andrews, 57 Ohio St.3d 86 (1991) ( articulable facts justify intrusion in stops)
- State v. Layne, 2011-Ohio-3763 (2011) (totality of circumstances; reasonable officer perspective)
- State v. Jimenez, 2012-Ohio-3318 (2012) (articulable facts; stop justified in context)
- Adams v. Williams, 407 U.S. 143 (1972) (brief stop to determine identity)