State v. Peek, 2017 Ohio 4427

On June 5–6, 2016 officer Anthony Southard ran random plate checks and learned dispatch indicated the registered owner’s license was suspended with limited (work) privileges.
At 12:45 a.m. Officer Southard stopped Benjamin Peek’s vehicle to verify driving privileges; he had observed no traffic violation prior to the stop.
Peek told the officer he had work privileges but could not produce them or registration/insurance; he was cited for driving under an OVI suspension.
Peek moved to suppress, arguing the stop lacked reasonable articulable suspicion because the officer had only a LEADS hit showing limited privileges and no facts indicating illegal driving.
The trial court denied the motion to suppress; Peek pleaded no contest and was convicted. He appealed the denial of the suppression motion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Peek)	Held
Whether the stop was supported by reasonable, articulable suspicion	Late hour + LEADS showing suspended license with limited privileges gave officer reasonable suspicion to stop and verify privileges	Dispatch info alone (suspended with limited privileges) plus lack of observed violation did not justify a stop	Stop was reasonable: officer had articulable suspicion based on late hour and limited-privilege information

Terry v. Ohio, 392 U.S. 1 (Terry establishes that investigatory stops require reasonable, articulable suspicion)
Ornelas v. United States, 517 U.S. 690 (reasonable suspicion/probable cause determinations reviewed de novo on appeal)
State v. Bobo, 37 Ohio St.3d 177 (totality-of-the-circumstances test for investigatory stops)
State v. Fanning, 1 Ohio St.3d 19 (standard for appellate review of suppression findings of fact)
State v. Carlson, 102 Ohio App.3d 585 (reasonable suspicion is less than probable cause)
State v. Owens, 75 Ohio App.3d 523 (BMV/LEADS checks are not a Fourth Amendment search)