State v. Meyers, 2014 Ohio 1357

Around 12:20 a.m., Officer Smith stopped Meyers’ pickup for heavy window tint and a nonworking rear license-plate light; database query showed Meyers had been issued a concealed-carry license.
Officer Smith observed a handgun on the vehicle floor near the gas pedal; he drew his weapon, ordered Meyers out, handcuffed him, and placed him in the patrol car; officers detected odor of alcohol and observed signs of intoxication.
Meyers refused field sobriety tests; during a post-arrest inventory of the vehicle officers found an open action handgun, a loaded magazine on the floor, a holster, and a second loaded magazine in the glove box.
Meyers was charged with improperly handling firearms in a motor vehicle (R.C. 2923.16) and using weapons while intoxicated (R.C. 2923.15), along with two minor traffic infractions. He proceeded pro se at trial after waiving counsel; standby counsel was available.
The trial court suppressed statements made after Meyers was placed in the patrol car but before Miranda warnings; it denied suppression of statements made during the roadside stop. A jury convicted Meyers on both weapons counts.
On appeal the court affirmed the intoxication conviction, reversed the firearm-in-vehicle conviction due to improper jury instructions, and remanded for a new trial on that count.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Meyers validly waived right to counsel	State: waiver was valid; court properly advised and standby counsel was available	Meyers: waiver was not knowing, voluntary, and intelligent	Waiver valid under totality of circumstances; no deprivation of counsel
Whether pre-custodial roadside statements should be suppressed	State: questions during traffic stop were permissible (not custodial)	Meyers: statements after removal from truck and before cruiser custody should be suppressed	Statements during stop (before placement in cruiser) admissible; court suppressed only post-placement/pre-Miranda statements
Whether jury instructions on R.C. 2923.16 were erroneous	State: instructions were adequate for charge	Meyers: court gave inapplicable/obsolete statute language and omitted concealed-carry exemptions	Plain error found: improper/inapplicable instructions require new trial on firearm-in-vehicle count
Whether using-weapon-while-intoxicated conviction was against manifest weight	State: evidence of intoxication and possession supports verdict	Meyers: evidence insufficient (e.g., no sobriety tests)	Conviction affirmed; evidence (officers’ observations, odor, behavior, expert opinion) supports verdict

Faretta v. California, 422 U.S. 806 (defendant may waive counsel and proceed pro se if waiver is knowing and intelligent)
Berkemer v. McCarty, 468 U.S. 420 (routine traffic stops are noncustodial for Miranda purposes)
Terry v. Ohio, 392 U.S. 1 (officer safety justifies limited inquiries and reasonable measures when suspect may be armed)
State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression rulings)
State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight standard; appellate court as "thirteenth juror")
State v. Martin, 103 Ohio St.3d 385 (permitting appointment of standby counsel for pro se defendant)