State v. Robinson
2014 Ohio 579
Ohio Ct. App.2014Background
- Thompson, under arrest for a stolen car, provides police with drug information about a subject named YG.
- Tip describes YG as a black male in his twenties with black and red SUVs at Neville Street; claims his girlfriend (white) carries drugs.
- Officers corroborate existence of vehicles matching descriptions near the Neville Street complex but cannot verify YG’s future drug dealings.
- Thompson’s call is brief; officers do not corroborate any intended drug transaction at Taco Bell.
- Black SUV stops on Neville Street; search yields a BB gun, scale, and cash; Robinson arrested; Husk claims crack cocaine on her person.
- Searched address reveals 38 grams cocaine, weaponry, and substantial cash; Robinson charged with trafficking, possession, and weapons while under disability; suppression motion denied; Robinson pleads no contest and is sentenced.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was supported by reasonable suspicion. | Robinson | Robinson | Suppression granted; stop invalid for lack of reasonable suspicion. |
Key Cases Cited
- State v. Burnside, 100 Ohio St.3d 152 (Ohio 2003) (mixed law-and-fact review for suppression rulings)
- State v. Weisner, 87 Ohio St.3d 295 (Ohio 1999) (reasonable suspicion and corroboration standards for tips)
- White v. United States, 496 U.S. 325 (U.S. 1990) (reliability of anonymous tips and corroboration need)
- Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality of the circumstances test for tips)
- Florida v. J.L., 529 U.S. 266 (U.S. 2000) (tip reliability and predictive content affect reasonable suspicion)
- Alabama v. White, 496 U.S. 325 (U.S. 1990) (reliability of informants and corroboration standards)
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (stopping a vehicle constitutes a seizure under Fourth Amendment)
- Maumee v. Weisner, 87 Ohio St.3d 295 (Ohio 1999) (framework for assessing reasonable suspicion and corroboration)
