State v. Smith, 2017 Ohio 5845

At ~1:43 a.m. on June 11, 2016, OSP Sgt. Mark Menendez followed Leslee Smith after observing what he believed were lane-marking violations while she merged onto Vernon Heights Blvd.; he stopped her vehicle and drugs were found.
Smith was indicted for possession of cocaine and heroin (two fifth-degree felonies) and pleaded not guilty.
Smith moved to suppress, arguing dash‑cam video showed only a single brief tire contact with the white edge line and no crossing of the lane.
At the suppression hearing, the dash‑cam was played repeatedly; Menendez testified he had a different vantage point and observed two instances of drifting/going over the line and some weaving.
The trial court found the dash‑cam more probative than the trooper’s perception, concluded Smith’s vehicle stayed within its lane except for a ~1‑second instance where the right tires rode on the white edge line (not crossed), found no safety risk, and suppressed the evidence for lack of reasonable, articulable suspicion.
The State appealed, arguing the officer’s testimony and precedent (permitting stops when a motorist drifts over lane markings) supported the stop; the appellate court affirmed the suppression judgment.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Smith)	Held
Whether officer had reasonable, articulable suspicion to stop for R.C. 4511.33 (marked lanes)	Menendez’s testimony established two lane departures (including driving onto/over the white line); officer had a better vantage point than dash cam	Dash‑cam shows only a single brief tire contact with the white edge line and no crossing; driving remained within the lane and posed no safety risk	Court affirmed: dash‑cam more probative; no reasonable suspicion because vehicle did not leave lane or create safety risk
Whether brief contact with the lane line alone can support reasonable suspicion	State: driving onto the white line may be a violation; officer testimony alone can suffice	Smith: single brief contact is incidental and consistent with safe operation; no evidence it was unsafe or impracticable to remain in lane	Court: under the facts dash‑cam showed only incidental contact; officer’s broader account was not credited; suppression affirmed

State v. Bobo, 37 Ohio St.3d 177 (defines reasonable articulable suspicion in Ohio)
State v. Mays, 119 Ohio St.3d 406 (stopping valid where driver drifted fully outside lane multiple times)
State v. Burnside, 100 Ohio St.3d 152 (standard of review for suppression rulings — mixed question of law and fact)
State v. Roberts, 110 Ohio St.3d 71 (appellate courts accept trial court factual findings supported by competent, credible evidence)
State v. Batchili, 113 Ohio St.3d 403 (reasonable suspicion analysis considers the totality of circumstances)