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