State v. Tidwell (Slip Opinion), 175 N.E.3d 527

At ~8:00 PM a state trooper (Sergeant Illanz) stopped at a two-car crash in a Speedway parking lot; an unidentified Speedway customer yelled to him, “Hey, you need to stop that vehicle. That lady is drunk,” pointing to an SUV backing out.
Illanz watched the driver back out slowly, then drive slowly toward a busy road; he observed a blank stare and, within ~30 seconds of the tip, walked in front of the vehicle and stopped it.
On contact Illanz smelled alcohol, noted bloodshot/glassy eyes and slow, slurred speech; Deputy Reynolds arrived, performed field-sobriety tests, and arrested Tidwell for OVI.
Tidwell moved to suppress; the municipal court granted suppression, the First District affirmed, and the state appealed to the Ohio Supreme Court.
The central legal question: whether the trooper had reasonable suspicion to briefly detain Tidwell based on the unidentified, face-to-face tip plus the officer’s observations.
Ohio Supreme Court reversed: under the totality of the circumstances the brief investigatory stop was reasonable and did not violate the Fourth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an investigatory stop was justified by an unidentified face‑to‑face tip	Tidwell: the Speedway customer’s tip was effectively anonymous and lacked indicia of reliability; required police corroboration (no sufficient corroboration)	State: face‑to‑face contact gives the tip investigative value akin to a citizen informant and need not be heavily corroborated	Court: Under the totality of the circumstances the contemporaneous face‑to‑face report plus officer’s observations supplied reasonable suspicion; stop was lawful
Whether absence of prior erratic driving defeats reasonable suspicion	Tidwell: no erratic driving or accident before the stop shows lack of corroboration	State: officer observed blank stare and slow backing/driving toward a busy road; tip alleged immediate danger, enabling a brief check	Court: Lack of highway weaving was immaterial—the tip plus brief corroborating observations (blank stare, slow driving) justified a short safety stop

Terry v. Ohio, 392 U.S. 1 (establishes investigatory stop on reasonable suspicion)
Navarette v. California, 572 U.S. 393 (contemporaneous 9‑1‑1 report can supply reasonable suspicion)
Adams v. Williams, 407 U.S. 143 (known informant who approaches officer is more reliable and may justify stop)
Alabama v. White, 496 U.S. 325 (anonymous tip corroborated by predictive/confirmable detail may justify stop)
Florida v. J.L., 529 U.S. 266 (bare, anonymous tip lacking basis‑of‑knowledge or predictive detail is insufficient)
United States v. Sharpe, 470 U.S. 675 (no fixed time limit for Terry stops; examine officer diligence to confirm/dispel suspicion)
United States v. Arvizu, 534 U.S. 266 (totality‑of‑circumstances and officer experience in assessing suspicion)
United States v. Cortez, 449 U.S. 411 (totality‑of‑circumstances framework for reasonable suspicion)
Maumee v. Weisner, 87 Ohio St.3d 295 (Ohio framework distinguishing anonymous, known, and identified citizen informants)
Illinois v. Wardlow, 528 U.S. 119 (Terry stops accept risk of stopping innocents; stop is minimal intrusion)