State v. Matheney, 2016 Ohio 7690

On March 11, 2015, Kettering officer Kevin Sanford stopped a vehicle driven by Larry Matheney after observing a turn-signal violation and a broken taillight.
During the stop (called in at 2:09 a.m.), Sanford collected IDs, noted Matheney’s nervousness and furtive movements toward a bag on the rear seat, and asked dispatch for a canine unit.
Backup officer Maloney observed Matheney reach toward the back seat; officers removed Matheney from the car and conducted a pat-down for officer safety (no weapon found).
The canine unit arrived roughly 21 minutes after the stop; the dog alerted within 3–5 minutes of arrival.
Officers searched the alerted vehicle, found a loaded handgun, drug paraphernalia, marijuana, and documents bearing Matheney’s name; Matheney was indicted on two fourth-degree felony weapons counts.
The trial court denied Matheney’s motion to suppress; Matheney appealed, arguing (1) the initial stop lacked reasonable suspicion/probable cause and (2) the stop was unreasonably prolonged by the canine sniff.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the initial stop lawful?	Sanford observed traffic violations (failure to signal, broken taillight); thus stop was valid.	Matheney contended there was no basis for the stop and that a hand signal might have been used.	Stop was lawful: officer observed violations in his presence and trial court credited the officer’s testimony that no hand signal was seen.
Did officers have authority to detain and pat-down Matheney?	Furtive, abrupt movement toward the back seat presented officer-safety concerns—reasonable to remove and pat-down.	Matheney argued movement did not justify prolonging detention or pat-down.	Pat-down was justified for officer safety given observed reaching toward reachable bag.
Did the canine sniff unreasonably prolong the stop?	Canine sniff occurred while officers were still completing tasks (running checks, writing citation) and followed intervening safety procedures; detention was not extended beyond reasonable time.	Matheney argued the detention was prolonged solely to await the canine unit.	Held reasonable: total duration (~24–26 minutes) was not excessive given intervening pat-down and ongoing citation/computer checks.
Should evidence from the subsequent vehicle search be suppressed?	Evidence found after a lawful stop, justified pat-down, and a canine alert is admissible.	Matheney sought suppression, claiming Fourth Amendment violation.	Denied suppression; evidence admissible.

Whren v. United States, 517 U.S. 806 (officer may stop vehicle based on observed traffic violation regardless of subjective intent)
Delaware v. Prouse, 440 U.S. 648 (random stops implicate Fourth Amendment; traffic stops must be reasonable)
Rodriguez v. United States, 575 U.S. 348 (a traffic stop becomes unlawful if prolonged beyond time reasonably required to complete mission; critical question is whether dog sniff added time)
Illinois v. Caballes, 543 U.S. 405 (a dog sniff that does not prolong a lawful traffic stop does not violate Fourth Amendment)
State v. Burnside, 100 Ohio St.3d 152 (appellate review standard for suppression; trial court findings of fact entitled to deference)
Dayton v. Erickson, 76 Ohio St.3d 3 (officer may stop for observed traffic or equipment violations)
State v. Ramos, 155 Ohio App.3d 396 (duration of stop measured against time reasonably necessary to complete mission; officer diligence considered)