State v. McDonald
102 N.E.3d 635
| Ohio Ct. App. | 2017Background
- On Jan. 19, 2017, Fostoria Patrolman Brett Bethel, informed by a detective and afternoon patrol that Cory McDonald was suspected of drug trafficking and had been seen driving, ran McDonald’s driver-status in LEADS and learned McDonald’s license was invalid.
- Later that night Bethel observed a blue sedan he recognized as McDonald’s driving past and identified McDonald as the sole occupant (noting distinctive eyeglasses).
- Bethel stopped the vehicle based on his knowledge that McDonald did not have a valid license; contraband was found and McDonald was arrested.
- McDonald moved to suppress, arguing (1) improper/unauthorized LEADS check, (2) the LEADS check and stop were “random” in violation of the Fourth Amendment, and (3) the stop was a pretext to investigate drug activity.
- The trial court denied the motion to suppress; McDonald pled no contest to multiple charges and appealed the suppression ruling.
- The appellate court affirmed, holding Bethel’s LEADS query was for a legitimate law‑enforcement purpose, the stop was supported by probable cause (driving without a license), and any subjective investigatory motive did not render the stop unconstitutional.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of LEADS query | Bethel’s LEADS check was a legitimate law‑enforcement use to verify license status after receiving tips. | LEADS check was improper/random and thus unlawful. | Held: Query was for a legitimate law‑enforcement purpose and lawful. |
| Random stop doctrine (Prouse) | Stop was based on observed violation; not random. | Characterized the status check as “random,” arguing random checks are unconstitutional. | Held: The stop was not a random, suspicionless traffic stop—Bethel had actual knowledge McDonald lacked a license. |
| Pretextual stop (subjective motive) | Even if Bethel suspected drug activity, the stop was justified by the observed traffic violation. | The stop was pretext to investigate narcotics, so invalid. | Held: Pretextual motive irrelevant where objective justification (probable cause for traffic violation) existed. |
| Suppression remedy | Evidence from lawful stop should be admitted. | Evidence should be suppressed if stop or query unlawful. | Held: Suppression denied; evidence admissible because stop and query were lawful. |
Key Cases Cited
- Delaware v. Prouse, 440 U.S. 648 (1979) (random stops of vehicles to check driver license/registration violate Fourth Amendment)
- Terry v. Ohio, 392 U.S. 1 (1968) (established reasonable, articulable suspicion standard for investigatory stops)
- United States v. Mendenhall, 446 U.S. 544 (1980) (test for when an encounter constitutes a seizure)
- Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (an objectively justified stop is valid even if officer had ulterior motives)