State v. Petty, 134 N.E.3d 222

Trooper observed Petty driving slowly at ~1:00 a.m., stopping at a flashing red signal, then turning left onto a four‑lane roadway into the far outside (rightmost) lane.
Trooper initiated a traffic stop citing a marked stop‑bar violation and an improper left turn; smelled alcohol, conducted field sobriety tests (failed), and Petty refused chemical tests.
A K‑9 sniff and subsequent search produced marijuana and paraphernalia; Petty was charged with OVI and drug offenses and moved to suppress evidence from the stop.
The trial court found no marked stop‑bar violation on the dashcam but concluded Petty made an improper left turn under R.C. 4511.36(A)(2) and denied the suppression motion.
On appeal, the court held the left‑turn statute does not require turning into the lane nearest the center line, but the trooper’s contrary belief was an objectively reasonable mistake of law under Heien, so the stop was supported by reasonable suspicion; conviction affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by reasonable suspicion based on a marked stop‑bar violation	Trooper: Petty stopped with front tires beyond the marked stop bar	Petty: Dashcam and testimony show officer couldn’t reliably determine tire position; no stop‑bar violation	Court: Trial court and appellate court found no stop‑bar violation; no reasonable suspicion based on that ground
Whether the stop was supported by reasonable suspicion based on an improper left turn / statutory interpretation of R.C. 4511.36(A)(2)	Trooper/State: Turning into the far outside lane violated R.C. 4511.36(A)(2)	Petty: Statute requires squaring into the turn but does not mandate entering the lane nearest the center line; turn was lawful	Court: Statute does not prohibit turning into the outside lane, but the trooper’s contrary interpretation was an objectively reasonable mistake of law under Heien; stop was justified

Heien v. North Carolina, 574 U.S. 54 (2014) (reasonable mistake of law can supply reasonable suspicion for a stop)
Whren v. United States, 517 U.S. 806 (1996) (officer’s subjective motives irrelevant where objective basis for stop exists)
Bowling Green v. Godwin, 110 Ohio St.3d 58 (2006) (officer need not correctly predict a conviction; objective reasonableness controls)
Brinegar v. United States, 338 U.S. 160 (1949) (Fourth Amendment allows reasonable mistakes by officers)
Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (traffic stops valid where officer observes a traffic offense)
State v. Kirkpatrick, 97 N.E.3d 871 (1st Dist. 2017) (interpreting R.C. 4511.36(A)(2) to permit turning into outside lane)