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State v. Moore
2025 Ohio 1326
Ohio Ct. App.
2025
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Background

  • Robert Lee Moore, Jr. was stopped by Cambridge Police for failing to use a turn signal when bearing left at an intersection where Dewey Avenue ends at Wheeling Avenue/North 5th Street.
  • During the stop, drugs were discovered in Moore's vehicle.
  • Moore was indicted for possessing a fentanyl-related compound.
  • Moore filed a motion to suppress, arguing the stop was not justified because his maneuver did not constitute a “turn” requiring a signal under Ohio law.
  • The trial court denied the motion, finding probable cause for the stop, and Moore later pled no contest and received three years of community control.
  • On appeal, Moore challenged solely the denial of his suppression motion.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the officer had probable cause to stop Moore for failing to use a turn signal at the intersection Moore made only a minor curvature, not a legal "turn"; thus, no violation occurred The turn or leftward movement required a signal under R.C. 4511.39 Officer had probable cause; stop was lawful

Key Cases Cited

  • Whren v. United States, 517 U.S. 806 (traffic stop reasonable if police have probable cause to believe a traffic violation occurred)
  • Dayton v. Erickson, 76 Ohio St.3d 3 (traffic violation provides sufficient justification for a stop)
  • State v. Mills, 62 Ohio St.3d 357 (trial court is best positioned to resolve factual and credibility disputes in suppression hearings)
Read the full case

Case Details

Case Name: State v. Moore
Court Name: Ohio Court of Appeals
Date Published: Apr 14, 2025
Citation: 2025 Ohio 1326
Docket Number: 2024 CA 000018
Court Abbreviation: Ohio Ct. App.