State v. Wade, 2017 Ohio 1319

Officer Elliott observed a silver car near a house suspected of drug trafficking and saw a black male walk away; he later followed the same vehicle because its front windows were heavily tinted and the driver signaled left then turned right at the intersection.
Elliott stopped the vehicle (driver: Brenda Hoose; passenger identified as "Rich," later Richard Wade Jr.), cited the signal change and excessive tint, and called for a K-9 unit based on suspected drug activity.
K-9 Officer Bell arrived within about one minute and walked his dog, Ricky, around the exterior; Ricky alerted to narcotics after ~30 seconds while Elliott was still awaiting dispatch checks on identity/registration.
Officers removed Hoose and Wade from the car for safety; during a Terry pat-down of Wade, Elliott felt a crunchy wrapped object in Wade’s pants, retrieved it (with Wade’s alleged consent), and found a bag with 230 Percocet and 30 Xanax (no prescription). Wade was arrested; subsequent search incident to arrest recovered cash and phones.
Wade was indicted for drug trafficking and possession of counterfeit controlled substances, moved to suppress the stop, the extended detention/dog sniff, and the search; the trial court denied suppression, Wade pled no contest, was convicted and sentenced, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Lawfulness of traffic stop	Stop valid: observed signal violation and excessive tint	Stop unreasonable; lacked lawful basis	Stop lawful — officer observed a signal change like in Wooster and excessive tint, providing reasonable suspicion to stop
Duration/extension of stop for K-9 sniff	Dog sniff occurred while officer was completing traffic tasks and did not prolong stop	Stop was impermissibly extended to conduct a dog sniff absent reasonable suspicion	No unlawful extension — K-9 arrived quickly and sniff occurred concurrently with routine checks, so it did not prolong the stop (Rodriguez applied)
Probable cause based on K-9 alert for further search	Totality of circumstances (tips, vehicle location, tint, nervous passenger, K-9 alert) gave probable cause	K-9 alert alone insufficient; search and seizure of person/contents unlawful	Search upheld — decision rested on totality (informant info, observations, nervous behavior, K-9 alert); pat-down for safety revealed the contraband and Wade allegedly consented to removal
Consent to removal of item	Officer testified Wade consented to removal of baggie	Wade denied consent at later hearing	Court credited officer’s testimony; evidentiary dispute resolved for the state and did not render search unconstitutional

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (extending a traffic stop to conduct a dog sniff requires independent reasonable suspicion)
Terry v. Ohio, 392 U.S. 1 (1968) (officer safety frisk exception for weapons during investigative stops)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff not part of traffic mission but may be permissible if it does not extend the stop)
Florida v. Jimeno, 500 U.S. 248 (1991) (reasonableness of warrantless searches measured by totality and scope of consent)
State v. Burnside, 100 Ohio St.3d 152 (2003) (appellate standard of review for motions to suppress)
State v. Mays, 119 Ohio St.3d 406 (2008) (traffic-stop reasonable-suspicion standard when stop is based on a traffic violation)