State v. Steinbrunner, 2012 Ohio 2358

Steinbrunner was convicted of operating a vehicle with a prohibited BAC (0.08+) under R.C. 4511.19(A)(1)(d) after a stop at a McDonald’s drive-thru.
Johns, a citizen informant, described a vehicle and the driver in front of him as “drunk” and in need of police attention.
Officer Marks initiated an investigatory stop based on dispatch information and corroboration from the drive-thru attendant.
Steinbrunner’s BAC at the stop was .152.
Steinbrunner moved to suppress evidence; the court denied the suppression motion.
On appeal, Steinbrunner challenges the stop as lacking reasonable suspicion; the court affirms the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was justified by reasonable articulable suspicion	Steinbrunner argues Johns’ tip was non-specific and insufficient to justify a stop.	Steinbrunner contends no independent observed violation or reliable tip supported the stop.	Yes; stop supported by reasonable suspicion under totality of circumstances.

Maumee v. Weisner, 87 Ohio St.3d 295 (Ohio 1999) (reliance on dispatch information and corroboration for stops)
Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (exclusion of unlawfully obtained evidence; warrant requirement)
Hensley v. United States, 469 U.S. 221 (U.S. 1985) (tip can create reasonable suspicion if reliable)
Weisner, City of Maumee v., 87 Ohio St.3d 295 (Ohio 1999) (stopping authority based on dispatch with corroboration)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes reasonable articulable suspicion standard)
State v. Andrews, 57 Ohio St.3d 86 (Ohio 1991) (totality of circumstances standard for stops)
State v. Carter, 72 Ohio St.3d 545 (Ohio 1995) (clarifies appellate review of suppression rulings)
State v. Bobo, 37 Ohio St.3d 177 (Ohio 1988) (recognizes reliability of informant tip for stops)