State v. Troutman, 2012 Ohio 407

Troutman stopped at 1:00 a.m. for allegedly crossing the center line; Trooper Long activated camera after stopping him.
Trooper Long conducted standard checks and asked about illegal items; Troutman stated nothing illegal and later indicated money (about $3,000) in his pockets.
Trooper Long administered HGN and another nystagmus test; no impairment detected.
A canine unit was requested; Troutman repeatedly consented to a search but later revoked consent while still detained.
During the detention, Troutman was kept in the back of a patrol car; canine sniff ultimately indicated drugs after the stop extended beyond normal duration.
A suppression motion was denied; Troutman pleaded no contest to cocaine and drug possession counts; trial court sentenced to seven months, but this appeal challenges the suppression ruling.
The appellate court reversed the suppression ruling, concluding the stop was unreasonably lengthy and not diligently pursued, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was unlawful pretextual and thus suppressible	Troutman argues the stop was pretextual and lacked probable cause.	State contends stop based on a traffic violation; any ulterior motive does not defeat legality.	Yes; stop could be based on probable cause for the traffic violation, but the pretext argument is not dispositive on suppression.
Whether the duration of the stop exceeded the permissible time	Detention extended beyond necessity to issue a ticket and complete license checks.	State argues detention stayed within reasonable time and later justified by suspicion.	Yes; detention was unreasonably prolonged and not diligently pursued to confirm or dispel suspicions.
Whether the canine sniff was valid given the prolonged detention	Search should have occurred sooner once consent was given; delay taints the search.	Dog sniff permissible during a lawful detention; itinerary did not render it invalid.	No; because the stop was unduly prolonged and search was not diligently pursued, the dog sniff cannot validate the search.
Whether the circuit court correctly denied the suppression motion	Trial court erred by upholding exclusion of evidence.	Record supported suppression denial based on standard stop and pursuit standards.	No; suppression reversal is warranted due to unreasonable duration and investigative conduct.

City of Dayton v. Erickson, 76 Ohio St.3d 3 (1996) (probable cause for traffic stop permissible even with ulterior motives)
United States v. Caballes, 543 U.S. 405 (2005) (dog sniffs during lawful traffic stop are permissible; prolonged stop can render them unlawful)
Mapp v. Ohio, 367 U.S. 643 (1961) (exclusionary rule applies to unlawfully obtained evidence)
State v. Batchili, 113 Ohio St.3d 403 (2007) (reasonable time for traffic stop depends on diligent investigation)
State v. Smith, 117 Ohio App.3d 278 (1996) (reasonable duration for obtaining a ticket or warning during a stop)