State v. Sidey, 2019 Ohio 5169

On Feb. 19, 2019 Sgt. Alec Cooper stopped Corey Sidey after another officer (Officer Hamacher) radioed that Sidey’s vehicle had no front license plate; Cooper had also observed possible speeding but could not pace the car.
Cooper initiated the stop, asked for license/registration, and while speaking with Sidey detected an odor of alcohol; Sidey admitted drinking and was cited for OVI and for a license-plate display violation.
Sidey moved to suppress, arguing Cooper lacked reasonable, articulable suspicion because Cooper did not personally observe the missing front plate and Hamacher did not testify at the suppression hearing.
The trial court denied the motion to suppress; Sidey later pleaded no-contest to OVI under a plea agreement and appealed the suppression ruling.
The key factual point: the front plate was propped inside the front windshield and not visible in "plain view" from Cooper’s initial position behind the B‑pillar because the vehicle was modified; Cooper only saw it after Sidey pointed it out.
The court concluded Cooper permissibly relied on his partner’s radioed observation under the collective-knowledge doctrine and that the plate was not displayed in plain view, so the stop was supported by reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an officer may stop a vehicle based on another officer’s radioed observation that a front license plate was missing, absent that officer’s testimony	State: Yes — Cooper reasonably relied on Hamacher’s report; collective knowledge supplies reasonable suspicion; plate not in plain view	Sidey: No — Cooper lacked personal observation and Hamacher should have testified; plate in windshield satisfied statute	Stop valid: court held collective knowledge justified the stop; plate not in plain view; suppression denial affirmed

Mapp v. Ohio, 367 U.S. 643 (exclusionary rule for evidence from unconstitutional searches/seizures)
Berkemer v. McCarty, 468 U.S. 420 (1984) (standards for investigative traffic stops)
Hensley v. Williams, 469 U.S. 221 (1985) (officer may act on information from other officers/dispatch)
City of Xenia v. Wallace, 37 Ohio St.3d 216 (1988) (State bears burden to justify warrantless seizure at suppression hearing)
State v. Cook, 65 Ohio St.3d 516 (1992) (collective-knowledge doctrine permits reliance on facts known to the law‑enforcement body)
State v. Henderson, 51 Ohio St.3d 54 (1990) (collective knowledge and system-wide justification for stops)
Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (objective assessment of officer’s knowledge at time of stop)
City of Maumee v. Weisner, 87 Ohio St.3d 295 (1999) (officer may rely on information transmitted by others; State’s burden at suppression)
State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of review for suppression rulings: mixed questions of law and fact)