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State v. Reedy
2012 Ohio 4899
Ohio Ct. App.
2012
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Background

  • On December 23, 2010, a CVS parking lot patrol observed Reedy exit the lot and turn left onto a roadway without signaling.
  • Officer Robison stopped Reedy, then found oxycodone and alprazolam in his possession.
  • Suppression hearing: the stop was based on a alleged signal violation; Robison was the only witness for appellee.
  • The Perry County Court of Common Pleas denied the motion to suppress after findings of fact and conclusions of law.
  • Reedy withdrew not-guilty pleas, entered no contest pleas, and was sentenced to five years on Count One and 90 days on Count Two with related penalties.
  • On appeal, Reedy challenges the stop as unconstitutional, arguing no probable cause for the traffic stop.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the stop violated the Fourth Amendment Reedy argues the stop was premised on a mistake of law and lacking reasonable suspicion. State contends the stop was supported by a reasonable suspicion and that the officer reasonably believed a traffic violation occurred. Stop upheld; mistaken but reasonable law error permitted; suppression denied.

Key Cases Cited

  • United States v. Brignoni-Ponce, 422 U.S. 873 (1975) (reasonable suspicion standard for investigatory stops)
  • United States v. Sokolow, 490 U.S. 1 (1989) (interpretation of totality of circumstances in stops)
  • United States v. Arvizu, 534 U.S. 266 (2002) (totality of the circumstances in reasonable-suspicion analysis)
  • Katz v. United States, 389 U.S. 347 (1967) (Fourth Amendment safeguards and investigative stops)
  • Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (traffic stops based on observed violations permissible)
  • State v. Greer, 114 Ohio App.3d 299 (1996) (exceptional circumstances extend good-faith exclusionary rule for mistakes of law)
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Case Details

Case Name: State v. Reedy
Court Name: Ohio Court of Appeals
Date Published: Oct 17, 2012
Citation: 2012 Ohio 4899
Docket Number: 12-CA-1
Court Abbreviation: Ohio Ct. App.