State v. Parson
2013 Ohio 2763
Ohio Ct. App.2013Background
- Parson was convicted of Tampering With Evidence after a suppression ruling.
- The stop occurred after a police dispatch report from a known female informant alleging a gray Oldsmobile driver was intoxicated.
- Officers House and Harding stopped Parson’s gray vehicle four minutes after the tip.
- Parson provided a false name; a knife and crack cocaine were found during the stop and search incident to arrest.
- Parson admitted to removing what appeared to be crack from his hat and later spit it out.
- The trial court denied the suppression motion; Parson pled no contest and was sentenced to 12 months in prison.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was supported by reasonable suspicion | Parson argues the tip alone did not create reasonable suspicion | Parson argues the informant’s reliability was insufficient | No error; stop justified by tip reliability and timing |
Key Cases Cited
- Maumee v. Weisner, 87 Ohio St.3d 295 (Ohio 1999) (dispatch-based tips can justify stops if reliable)
- Terry v. Ohio, 393 U.S. 1 () (permits investigative stop with reasonable suspicion)
- Minnesota v. Dickerson, 508 U.S. 366 () (plain-view/ephemeral seizures exceptions to warrants)
- State v. Hipp, 2013-Ohio-1684 (Ohio 2013) (dispatcher tip reliability and corroboration issues in stops)