State v. Park, 2012 Ohio 4069

On January 26, 2011, a sobriety checkpoint operated on State Route 16 in Licking County, Ohio.
Karen Park entered the checkpoint lane but did not stop when directed by two troopers and was eventually stopped.
Park was charged with operating a motor vehicle under the influence, failure to reinstate a driver's license, and failure to comply with an order of a police officer.
Park moved to suppress the checkpoint and the stop, and the trial court denied the motions at the August 31, 2011 entry.
Park filed a motion to reconsider, a hearing was held January 6, 2012, and the trial court again denied suppression.
Park pled no contest on February 14, 2012, was found guilty on the charges, and was sentenced to 180 days in jail with 177 days suspended.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the checkpoint could alter stop frequency on subjective supervisory guidance	Park contends pattern changes were arbitrary.	State argues procedures and policy allowed frequency adjustments.	Denied; proper four-prong Goines/Hall compliance.
Whether officers had reasonable cause to stop for failure to comply given checkpoint administration	Checkpoint was unconstitutionally administered, undermining stop justifications.	Checkpoint met legal standards; driver failed to stop despite directives.	Denied; stop supported by lawful order and observed behavior.
Whether the conviction for failure to comply was against the manifest weight of the evidence	Argument reasserts illegality of stop and order.	Conviction supported by lawful order and Park's failure to stop.	Denied; evidence adequate to sustain the conviction.

State v. Hall, 2004-Ohio-3302 (Ashland App. No. 03-COA-064, 2004) (framework for evaluating roadblock constitutionality and predetermination)
State v. Goines, 16 Ohio App.3d 168 (1984) (four-part test for sobriety checkpoint legality)
Ornelas v. U.S., 116 S. Ct. 1657 (1996) (de novo review of reasonable suspicion and probable cause)