State v. Regulus, 986 N.E.2d 1105

This is an Ohio Court of Appeals ruling affirming a suppression ruling following Regulus’s no-contest plea to carrying a concealed weapon and having a weapon while under disability.
A suppression hearing occurred February 3, 2012 with deputies Baranyi and Rolfes as witnesses.
Baranyi observed Regulus and Ward walking behind a closed shopping center in a dimly lit, high-crime area.
They were not in an alley; Baranyi approached them after light was shined and asked for identification; Regulus lacked ID.
Baranyi believed they might be armed and conducted a frisk that revealed a handgun; Ward and Regulus were detained/arrested.
The trial court denied suppression; Regulus appealed challenging Terry stop grounds and the frisk justification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by reasonable suspicion	Regulus (State)	Regulus	Terry stop justified by totality of circumstances
Whether the frisk was justified by individualized suspicion Regulus was armed	State	Regulus	Weapons frisk affirmed based on totality of circumstances

State v. Andrews, 57 Ohio St.3d 86 (Ohio 1991) (establishes reasonable-suspicion standard for Terry stops in Ohio)
State v. Bobo, 37 Ohio St.3d 177 (Ohio 1988) (totality-of-the-circumstances test for stop/detention)
State v. Evans, 67 Ohio St.3d 405 (Ohio 1993) (limits on frisk when stop is lawful; need for reasonably believed weapon)
State v. Carter, 2004-Ohio-454 (Ohio Ct. App. 2004) (purple-light/spotlight approach discussed in stop context; not determinative)
Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (reasonable suspicion based on behavior in high-crime area; common-sense judgments)