State v. Mee
96 N.E.3d 1020
Ohio Ct. App.2017Background
- At ~1:59 a.m. Officer Spinks stopped Matthew Mee for drifting across a marked lane in Kettering, Ohio. Spinks ran LEADS/NCIC checks and a K-9 officer (Maloney) arrived within minutes.
- After checks revealed a past drug-related license suspension for one passenger, Spinks returned, asked for consent to search; Mee refused. Spinks then announced a planned free-air K-9 sniff and required occupants to exit; he also requested (and Mee allegedly consented to) a pat-down.
- During the pat-down, Spinks felt a bottle and a bag in Mee’s jacket pocket; on retrieving them he found pills that did not match the prescription label, leading to Mee’s handcuffing and investigative detention.
- As a passenger exited, officers observed two edibles that a passenger said were baked with marijuana and given by Mee; officers then performed a full search and found large quantities of drugs in a locked box in Mee’s bag.
- Trial court suppressed evidence from the vehicle search, concluding the stop was prolonged beyond the time reasonably required; the State appealed.
- The appellate majority reversed, holding the detention did not exceed the time reasonably necessary and that discovery of the pills gave officers reasonable suspicion to continue detention.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was unlawfully prolonged by unrelated investigatory actions (ask to search, K-9 sniff, pat-down) | The stop was not prolonged beyond reasonable time to complete traffic investigation; officers acted diligently and detention was within reasonable duration | Officer unlawfully extended the stop to conduct a drug investigation without reasonable suspicion; actions added time to the stop | Reversed trial court: detention did not exceed reasonable time; later discovery of inconsistent pills justified continued detention |
| Whether a free-air K-9 sniff during the stop requires separate reasonable suspicion | A dog sniff is permissible without additional suspicion so long as it does not extend the stop beyond reasonable time | Requesting a sniff (and related steps) without suspicion unlawfully expanded the stop under Rodriguez | Court applied duration-based standard: no unlawful extension where diligence shown and total time reasonable |
| Whether evidence found during a consensual pat-down/search created reasonable suspicion for further detention/search | Contradictory medication (bottle + bag of pills mismatching label) supported reasonable suspicion | Carrying prescription meds is lawful; such evidence alone insufficient for reasonable suspicion | Court found the mismatch and presence of bag/bottle supported reasonable suspicion to detain further and search |
| Whether officers could have conducted K-9 sniff while completing citation to avoid prolonging the stop | Officer diligence meant actions didn’t lengthen the stop; no improper delay to await dog | Officer should have completed traffic processing first; using presence of K-9 nearby doesn’t justify diverting from traffic purpose | Majority: timing and conduct show stop would have taken similar time; actions were within permissible duration |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes limits on investigatory stops and scope of brief detentions)
- Whren v. United States, 517 U.S. 806 (1996) (traffic stops are seizures subject to Fourth Amendment reasonableness)
- Illinois v. Caballes, 543 U.S. 405 (2005) (K-9 sniff during lawful traffic stop not a search so long as it does not prolong the stop)
- United States v. Place, 462 U.S. 696 (1983) (K-9 sniff of luggage is minimally intrusive and reveals only presence of contraband)
- Jacobsen, 466 U.S. 109 (1984) (no legitimate privacy interest in possession of contraband)
- Rodriguez v. United States, 135 S. Ct. 1609 (2015) (a stop justified by a traffic violation becomes unlawful if prolonged beyond time reasonably required to complete the mission)