State v. Tackett, 2011 Ohio 6711

Tackett was stopped for traffic violations on Colonel Glenn Highway around 2:00 a.m. and moved onto side roads after the stop.
Officer observed a strong odor of alcohol, glassy and bloodshot eyes, slurred speech, and head-leading-eye movement by Tackett.
Defendant exited the vehicle at the officer’s request; Trooper Howard conducted field sobriety tests after obtaining consent.
Tackett refused to submit to a chemical test to determine blood alcohol content.
A suppression motion was raised; the trial court denied in part and granted in part, and Tackett pleaded no contest to a charge under R.C. 4511.19(A)(2).
This appeal concerns whether the exit from the vehicle and subsequent field sobriety testing were lawful under reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exiting the vehicle violated suppression standards	Tackett lacked sufficient reasonable suspicion to continue detention after the stop.	The officer’s observations and safety considerations justified ordering Tackett to exit and perform tests.	Overruled; detention justified, field tests admissible

State v. Mills, 62 Ohio St.3d 357 (Ohio 1992) (defers to trial court on factual findings; appellate review of suppression de novo)
State v. Curry, 95 Ohio App.3d 93 (Ohio App.3d 1994) (appellate review of suppression findings; credibility not disturbed)
State v. Schiebel, 55 Ohio St.3d 71 (Ohio 1990) (police use of reasonable suspicion; standard for stop and frisk analysis)
State v. Schmitt, 101 Ohio St.3d 79 (Ohio 2004) (admissibility of lay witness testimony on nonscientific field sobriety tests)
State v. Lothes, 2007-Ohio-4226 (Ohio App. 2007) (observations on sobriety tests admissible to support probable cause)
Pennsylvania v. Mimms, 443 U.S. 106 (U.S. 1977) (safety-based exit from vehicle permitted during traffic stops)