State v. Sayler
2016 Ohio 7083
Ohio Ct. App.2016Background
- Early-morning single-vehicle crash on Route 71; a white Toyota SUV with heavy damage was found in the median and had a single occupant, Heather Sayler, who was uninjured.
- Trooper Dudas arrived, was told it was a single-vehicle crash, and found Sayler in a sheriff’s cruiser; he smelled a strong odor of alcohol, observed bloodshot/glassy eyes, and Sayler admitted drinking three beers.
- Trooper Dudas administered standardized field sobriety tests (HGN, walk-and-turn, one-leg stand); based on observations he arrested Sayler for OVI.
- Sayler moved to suppress, arguing lack of proof she was the driver, that the trooper failed to substantially comply with 2013 NHTSA standards for field sobriety testing, and that blood evidence was improperly obtained; the trial court suppressed the blood-test results for lack of proof the sample was refrigerated but denied other parts of the motion.
- Following a jury trial (with the blood results excluded), Sayler was convicted of OVI and failure to control; she appealed, arguing suppression should have been granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause to arrest for OVI (whether Sayler was operating the vehicle) | Sayler: State failed to prove by preponderance she was the driver, so arrest lacked probable cause | State (Trooper): Single-vehicle crash, only occupant present, odor of alcohol, bloodshot eyes, admission of drinking, poor SFST performance — these facts established probable cause | Court held probable cause existed under the totality of circumstances and affirmed denial of suppression |
| Substantial compliance with 2013 NHTSA field-sobriety standards (admissibility of SFST results) | Sayler: Trooper did not substantially comply with NHTSA manual; tests therefore unreliable | State: Trial court found substantial compliance based on officer testimony and video | Court affirmed denial of suppression because appellate record lacked the NHTSA manual excerpts and the stop video (appellant’s duty to provide complete record); presumption of regularity applied |
Key Cases Cited
- Burnside v. State, 100 Ohio St.3d 152 (Ohio 2003) (standard of review for suppression: trial court factual findings afforded deference; legal conclusions reviewed de novo)
- Homan v. State, 89 Ohio St.3d 421 (Ohio 2000) (probable cause for OVI judged by totality of circumstances at time of arrest)
- Schmitt v. State, 101 Ohio St.3d 79 (Ohio 2004) (officer observations of SFST performance are admissible for probable-cause analysis)
- Boczar v. State, 113 Ohio St.3d 148 (Ohio 2007) (state may prove NHTSA standards through testimony or by introducing the manual)