State v. Tyler
2013 Ohio 4673
Ohio Ct. App.2013Background
- Defendant-appellant Darius D. Tyler was indicted for possession of cocaine, a fifth degree felony.
- Tyler moved to suppress statements and evidence obtained at the scene, filed August 31, 2012, with a supplemental filing later.
- Hearing held February 20, 2013; Columbus Officers Daugherty and Andrews testified about the March 1, 2011 encounter following gunshots reports.
- Officers stopped Tyler for pedestrian in the roadway and conducted a Terry patdown for weapons during the investigation.
- Tyler resisted while pockets were being checked; officers observed a pill bottle, questioned pills’ ownership, and then learned of crack cocaine.
- Trial court denied suppression; Tyler pled no contest to possession of cocaine and was convicted and sentenced.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop expanded beyond its initial purpose without reasonable suspicion | Tyler | Tyler | No error; continued reasonable, articulable suspicion supported expansion |
Key Cases Cited
- State v. Owens, 2004-Ohio-5159 (10th Dist.) (expanded investigation requires reasonable suspicion)
- State v. Vanderhoff, 106 Ohio App.3d 21 (11th Dist. 1995) (expanded investigation needs reasonable suspicion)
- State v. Retherford, 93 Ohio App.3d 586 (2d Dist. 1994) (totality of circumstances governs investigative stops)
- State v. Morris, 2010-Ohio-1383 (10th Dist.) (police viewpoint and experience important in evaluating stops)
- State v. Bobo, 37 Ohio St.3d 177 (1988) (limits on stop duration and expansion under Terry)
- State v. Andrews, 57 Ohio St.3d 86 (1991) (reasonable suspicion standard in investigative stops)