State v. Saunders
2013 Ohio 2052
Ohio Ct. App.2013Background
- Saunders was convicted of burglary in Fayette County Common Pleas Court after a jury trial.
- A deputy stopped Saunders’ vehicle on I-71 after responding to a burglary-in-progress description matching his Jeep.
- The stop occurred after observing a vehicle and occupants that conformed to the description provided by dispatch.
- Saunders moved to suppress, but the trial court denied the motion; suppression was affirmed on appeal.
- The victim could not identify Saunders at trial, though clothing and vehicle descriptions matched Saunders and a female passenger.
- The court held the stop was supported by reasonable, articulable suspicion and the evidence was sufficient and not against the manifest weight.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop violated the Fourth Amendment and Ohio Constitution. | Saunders argues lack of reasonable suspicion. | Saunders contends stop based on unparticularized hunch. | Stop supported by reasonable, articulable suspicion. |
| Whether the conviction is supported by the manifest weight and is supported by sufficient evidence. | Evidence is circumstantial and insufficient; victim could not identify Saunders. | Evidence, including vehicle description and clothing, supports guilt. | Conviction affirmed for weight and sufficiency. |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (investigative stop requires reasonable suspicion)
- State v. Andrews, 57 Ohio St.3d 86 (Ohio 1991) (facts must give rise to reasonable suspicion)
- State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (distinguishes weight from sufficiency; credibility considered)
- Jenks, 61 Ohio St.3d 259 (Ohio 1991) (test for sufficiency: rational trier of fact could find elements beyond reasonable doubt)