State v. Sinha, 2013 Ohio 5203

Undercover surveillance linked Sinha to an apartment known for trafficking high-grade marijuana; detective informed Officer Flick of this connection.
Flick observed Sinha commit three traffic violations (excess speed, missing front plate, ran a red light) and stopped the car on that basis.
During the stop, marijuana shake was observed in the backseat by Flick and his partner, and Sinha’s past drug arrests were revealed through police database checks.
Sinha consented to a vehicle search after being told a citation would be issued; he sat in the cruiser briefly and spoke with Flick.
Search of the car yielded five GPS units, two phones, two iPods in a backpack; a beer can and a pipe with burnt marijuana residue were found.
Criminal charges were filed for four counts of receiving stolen property and drug/paraphernalia related offenses; Sinha moved to suppress the search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the search consent voluntary after the stop ended?	State argues consent was voluntary given during a valid, ongoing investigation.	Sinha argues consent was involuntary because the traffic stop had ended.	Consent found voluntary; suppression denied.
Did reasonable suspicion justify continuing the detention after the traffic stop?	State contends observations and detective information created reasonable articulable suspicion.	Sinha contends the stop ended and there was no basis to extend detention.	Yes; totality of circumstances supported detaining for further investigation.

State v. Smith, 12th Dist. Warren App. No. CA2012-03-022, 2012-Ohio-5962 (2012) (reasonable-articulable-suspicion framework for extending stop)
State v. Robinette, 80 Ohio St.3d 234, 241 (1997) (1997) (detention extensions require reasonable suspicion)
State v. Bobo, 37 Ohio St.3d 177, 178 (1988) (1988) (basis for reasonable suspicion standard)
Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (voluntariness of consent requires free and voluntary consent)
State v. Andrews, 57 Ohio St.3d 86, 87 (1991) (1991) (totality-of-the-circumstances test for police action)
State v. Troutman, 2012-Ohio-407, 3d Dist. Marion No. 9-11-17, ¶ 25 (2012) (inferences from officer experience inform reasonable suspicion)
State v. Smith, 2012-Ohio-5962 (2012) (refinement of detention and consent analysis (cited multiple times in opinion))
State v. Christopher, 12th Dist. No. CA2009-08-041, 2010-Ohio-1816 (2010) (credibility-based voluntariness determination)
State v. Arvizu, 534 U.S. 266, 273-274 (2002) (2002) (totality of the circumstances standard for suspicion-based stops)