State v. Panaro, 108 N.E.3d 1187

Around 1:00 a.m. on July 30, 2015, Officer Sandella followed and then stopped Jason Panaro after observing alleged turn-signal violations at an intersection near a bar.
Sandella testified Panaro failed to signal when changing into the left-turn lane and did not signal for the required 100 feet before making a left turn; dash‑cam video showed Panaro signaled before the left turn but was ambiguous about signaling while changing lanes or the distance of signal activation.
After the stop, Panaro took about 45 seconds to pull over, initially could not recall which bar he left, had to be reminded about his insurance card, and admitted drinking three beers; the officer detected an odor of alcohol from the vehicle.
The trial court suppressed the results of two field sobriety tests as not in substantial compliance with procedures but otherwise denied suppression; Panaro pleaded no contest to OVI (R.C. 4511.19(A)(1)(a)) and appealed.
The court of appeals reviewed (1) whether the trial court’s factual finding that Panaro failed to use his turn signal (including 100-foot requirement) was supported by competent, credible evidence and (2) whether the officer had reasonable, articulable suspicion to detain Panaro to administer field sobriety tests.

Issue	Panaro's Argument	State's Argument	Held
Whether the trial court’s finding that Panaro failed to use his turn signal (including 100 feet prior to turning) is supported by competent, credible evidence	Video shows Panaro had his turn signal on at least 100 feet before the left turn, so no traffic violation occurred	Officer’s testimony and video support the finding that Panaro did not signal when changing lanes and did not signal for 100 feet before turning	Court affirmed: officer testimony found credible and video did not contradict; the 100‑foot finding was supported by competent, credible evidence, so the stop was justified
Whether the officer had reasonable, articulable suspicion to detain Panaro for field sobriety testing after the stop	No reasonable suspicion to further detain; initial stop impermissible or insufficient indicators for DUI investigation	Multiple factors (signal violations, slow/long response to emergency lights, odor of alcohol from vehicle, admission of drinking, confused/memory lapses) together provided reasonable suspicion	Court affirmed: under totality of circumstances the officer had reasonable suspicion to detain and conduct field sobriety testing

State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of review for suppression: trial court factual findings are upheld if supported by competent, credible evidence; appellate court reviews legal conclusion de novo)
State v. Mills, 62 Ohio St.3d 357 (1992) (trial court as factfinder resolves credibility and factual disputes at suppression hearings)
Maumee v. Weisner, 87 Ohio St.3d 295 (1999) (investigative stop requires specific and articulable facts supporting reasonable suspicion)
Terry v. Ohio, 392 U.S. 1 (1968) (Fourth Amendment framework for investigative stops based on reasonable suspicion)
State v. Bobo, 37 Ohio St.3d 177 (1988) (reasonable‑and‑cautious‑officer standard and considering totality of circumstances for stops)
State v. McNamara, 124 Ohio App.3d 706 (4th Dist.) (appellate courts independently determine whether facts satisfy legal standard after accepting trial court’s factual findings)