State v. Stadelman
2013 Ohio 5035
Ohio Ct. App.2013Background
- Defendant Ryan Stadelmann made a "wide" left turn from the lane immediately left of center on Drake Road onto Madison Road, ending up in the far right (curb) lane.
- Sergeant Thomas Bloomberg observed the turn and stopped Stadelmann, believing it violated R.C. 4511.36(A)(2) (statute governing left turns at intersections).
- Stadelmann moved to suppress evidence, arguing the stop was unlawful because his turn was legal under the statute; the trial court denied suppression and he pled no contest to OVI (R.C. 4511.19(A)(1)(d)).
- On appeal, the sole issue was whether the officer reasonably believed a traffic violation had occurred, making the stop lawful.
- The majority found the statutory language susceptible to the officer’s interpretation and held the stop was objectively reasonable; the dissent maintained the statute is plain and the stop unlawful.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the traffic stop based on an objectively reasonable belief of a left-turn violation under R.C. 4511.36(A)(2)? | Officer’s observed "wide" turn could reasonably be read to require turning into the lane nearest the center line; thus reasonable suspicion existed. | Stadelmann’s turn complied with the statute’s plain language (leaving intersection right of center); no violation occurred, so stop was unlawful. | Court upheld the stop: an objectively reasonable officer could interpret the statute to prohibit the executed turn, so suppression denial affirmed. |
Key Cases Cited
- State v. Greer, 114 Ohio App.3d 299 (2d Dist. 1996) (good-faith exception may extend to reasonable mistakes of law where statute is ambiguous)
- Bowling Green v. Godwin, 110 Ohio St.3d 58 (Ohio 2006) (officer need only have objectively reasonable suspicion; need not correctly predict conviction)
- Richlin v. Gooding Amusement Co., 113 Ohio App. 99 (8th Dist. 1960) (discussion of left-turn statute’s aim to prohibit "cutting the corner")
