State v. Slaughter
2018 Ohio 105
Ohio Ct. App.2018Background
- Trooper Alex Burnett, in a marked cruiser, followed a red Nissan Altima (driven by Tyrone Slaughter) on North Bend Road after observing the vehicle drift from the left lane about one to two feet into the right lane.
- Burnett accelerated, stopped the vehicle, performed field-sobriety tests, and arrested Slaughter for OVI; Slaughter later pled no-contest to OVI (prohibited BAC) and a marked-lanes violation.
- Slaughter moved to suppress, arguing the stop lacked reasonable articulable suspicion or probable cause.
- Cruiser-camera video admitted at the hearing showed a separate, later marked-lanes movement by Slaughter near an intersection (which Burnett testified he had not observed because of distance and glare).
- The trial court denied suppression, relying on the second marked-lanes violation seen on the video as the basis for probable cause; the court of appeals affirmed for different reasons (relying on Burnett’s unrebutted testimony about the first violation).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was supported by reasonable articulable suspicion or probable cause | Burnett observed a lane deviation (plaintiff/appellee argues stop was lawful). | Slaughter: stop unlawful because officer lacked reasonable suspicion/probable cause; trial court relied on a violation the trooper did not observe. | Court: Affirmed — Burnett’s unrebutted testimony that he saw the first marked-lanes deviation supplied reasonable articulable suspicion to stop. |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (Fourth Amendment reasonableness of traffic stops)
- Dayton v. Erickson, 76 Ohio St.3d 3 (Ohio standard: probable cause justifies traffic stop)
- State v. Mays, 119 Ohio St.3d 406 (probable cause subsumes reasonable articulable suspicion; officer witnessing violation supplies probable cause)
- State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression: factual findings deferred, legal questions reviewed de novo)
- Bowling Green v. Godwin, 110 Ohio St.3d 58 (totality of circumstances test for traffic-stop reasonableness)
- State v. Evans, 67 Ohio St.3d 405 (probable cause vs. reasonable suspicion relationship)