State v. Mosley, 2021 Ohio 3472

Undercover officer surveilling a high-drug area observed Mosley stopped in traffic talking to occupants of another car and radioed a uniformed officer (Officer Murrell) to stop him for impeding traffic.
The undercover followed as Mosley drove off and reported seeing him make furtive movements as if hiding something; Murrell stopped Mosley after receiving that radio broadcast.
Officer Murrell, when later questioned, could not articulate the specific traffic offense or where it occurred, but ordered Mosley out of the vehicle.
Mosley refused consent to search but admitted there was marijuana; a K-9 arrived and alerted, and officers found a bag of crack cocaine in the center console.
The trial court granted Mosley’s motion to suppress the drug evidence, concluding Murrell lacked constitutional justification to stop the vehicle; the state appealed.
The appellate court reversed, holding the stop was supported by probable cause based on the undercover officer’s radio transmission and law-enforcement community knowledge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was constitutional when the detaining officer lacked personal knowledge of the violation	Stop valid because Murrell had probable cause through the undercover officer’s radio report; law‑enforcement collective knowledge supplies probable cause	Stop invalid because Murrell could not articulate the traffic offense or where it occurred	Reversed suppression; stop constitutional under the collective-knowledge rule (Cook/Henderson)
Whether evidence from the stop (ordering out, K-9 alert, cocaine discovery) was admissible given the stop	Subsequent actions were permissible because the initial stop was lawful	Mosley did not challenge these actions at length below	Court noted these actions were permissible and not separately contested once the stop was lawful

State v. Cook, 65 Ohio St.3d 516 (1992) (collective law-enforcement knowledge can establish probable cause even if the arresting officer lacks the information)
State v. Henderson, 51 Ohio St.3d 54 (1990) (officer’s report to another officer may supply probable cause for warrantless stops/arrests)
Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (probable cause for a traffic violation justifies a stop even if officer has an ulterior investigative motive)
Whiteley v. Warden, 401 U.S. 560 (1971) (principles supporting use of others’ observations to establish probable cause)
United States v. Hensley, 469 U.S. 221 (1985) (officer reliance on flyers/broadcasts from other officers can justify stops under Fourth Amendment)