State v. Thomas, 2013 Ohio 3411

Deputy Lewis stopped a dark minivan on I-71 in Warren County for a possible lane violation; the van’s speed fluctuated and drifted over the center line.
Thomas was a passenger; the van was rented, with Thomas claiming rental from Boston; Thomas offered limited details on where they had traveled.
A canine search followed a warrant check; an air freshener and bags were observed; marijuana was found after a canine alert and a search of the van.
Graham and Thomas gave conflicting explanations for their travel; they had been to Boston and Cincinnati and were en route back home.
Ohio detained Thomas under the IAD framework after detainers and extradition matters; Thomas was eventually brought from federal custody to Ohio for trial and was convicted of possession and trafficking in marijuana, receiving a six-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of stop and duration for canine sniff	Thomas; Graham argued stop improper, but Graham held that stop lawful	Thomas; Johnson-based challenge; argued detainment exceeded permissible time	Stop lawful; detention duration reasonable; suppression denied
IAD compliance and anti-shuttling violation	Thomas argues IAD violated by detaining and not returning before trial	No IAD violation; trial conducted after arrival in Ohio	No IAD violation; denial affirmed

State v. Graham, 2009-Ohio-2814 (Ohio 2009) (affirms denial of suppression where stop and duration were proper)
Dayton v. Erickson, 76 Ohio St.3d 3 (Ohio 1996) (probable cause or reasonable suspicion required for traffic stops)
State v. Cochran, 2007-Ohio-3353 (Ohio 2007) (mixed question of law and fact in suppression rulings)
State v. Batchili, 2007-Ohio-2204 (Ohio 2007) (articulable facts required for extended detention for canine walkaround)
State v. Gibson-Sweeney, 2006-Ohio-1691 (Ohio 2006) (lane violation as basis for traffic stop; reasonable suspicion)