State v. Rodgers
2017 Ohio 8211
| Ohio Ct. App. | 2017Background
- On Oct. 12–13, 2016 Newark police investigated a reported stolen firearm belonging to Wendy Faine. Texts and photos on a relative’s phone implicated Jacob Faine‑Carpenter and showed the gun; Faine‑Carpenter later said he gave the gun to Jordan Rodgers to hold while he was jailed.
- Police arranged recorded calls between Faine‑Carpenter and Rodgers; in the calls Rodgers admitted possessing the gun and agreed to deliver it. Rodgers later told Faine‑Carpenter to come to his home to retrieve the gun.
- Surveillance was established at Rodgers’ residence; Rodgers left and was stopped by officers. A search of his vehicle produced a bag with the handgun and ammunition reported stolen.
- Rodgers moved to suppress, arguing the warrantless arrest/stop lacked reasonable, articulable suspicion/probable cause. The trial court denied the motion to suppress.
- Rodgers pleaded no contest to weapons under disability, improperly handling a firearm in a motor vehicle, possession of drug paraphernalia, and possession of marijuana. The court sentenced him (merging firearm counts for sentencing) and imposed remaining post‑release control from a prior conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers had probable cause to make a warrantless arrest and search of Rodgers | Facts (texts, photos, recorded admissions, surveillance) gave probable cause Rodgers possessed the stolen firearm and violated weapons‑under‑disability statute | Arrest/stop lacked reasonable, articulable suspicion and thus evidence should be suppressed | Court affirmed denial of suppression: totality of circumstances supported probable cause for the arrest/search |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (1996) (probable cause and reasonable‑suspicion determinations reviewed de novo)
- Beck v. Ohio, 379 U.S. 89 (1964) (probable cause standard for arrests)
- Illinois v. Gates, 462 U.S. 213 (1983) (totality‑of‑the‑circumstances test for probable cause)
- State v. Long, 127 Ohio App.3d 328 (1998) (standard of review for suppression rulings)
- State v. Brooks, 75 Ohio St.3d 148 (1996) (trial court as factfinder in suppression hearings)