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