State v. Richardson, 2016 Ohio 5801

On June 13, 2013, Columbus police patrolling a known high‑crime apartment complex encountered Amir Richardson in an interior hallway; officers had information of drug activity in the building.
Officers greeted Richardson, asked whether he lived there and whether he was visiting; Richardson walked past them, exited the building carrying a pizza box, and sat outside to eat.
Officers asked for identification; Richardson gave his name and birthdate and the officers ran a warrant check over the radio.
While Richardson moved toward a dumpster to discard the pizza box, the warrant check revealed an outstanding arrest warrant; officers then arrested him.
After arrest, an officer returned to the hallway where Richardson had been standing and found a plastic baggie containing crack cocaine; Richardson later waived Miranda and admitted ownership of the drugs.
Richardson moved to suppress the cocaine and his statement, arguing the initial encounter was not consensual and, alternatively, that the officers lacked reasonable suspicion for a Terry stop; the trial court denied the motion, Richardson pled no contest, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the encounter and questioning constituted a seizure requiring suppression	State: The contact was a consensual encounter; officers merely requested ID and ran a warrant check, then arrested on an outstanding warrant, so evidence is admissible	Richardson: A reasonable person would not have felt free to leave; the contact was a nonconsensual seizure and lacked reasonable suspicion for seizure	Court: The encounter was consensual under the totality of circumstances; officers did not display force or authority that would make a reasonable person feel restrained, so suppression was properly denied

State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of appellate review for suppression rulings: accept trial court’s factual findings if supported by competent, credible evidence; apply de novo to legal conclusions)
State v. Mills, 62 Ohio St.3d 357 (1991) (trial court best positioned to resolve factual questions and witness credibility at suppression hearings)
State v. Fanning, 1 Ohio St.3d 19 (1982) (appellate courts accept trial court’s factual findings when supported)
Florida v. Bostick, 501 U.S. 429 (1991) (defining consensual encounters and observing that an individual is free to decline police requests and terminate the encounter)
State v. Taylor, 106 Ohio App.3d 741 (1995) (consensual encounter where officer asked a few questions in a public place without display of force)
State v. McDaniel, 91 Ohio App.3d 189 (1993) (approach and questioning in apartment hallway did not constitute a seizure when subject was free to walk away)