State v. Ward, 2011 Ohio 1261

Trooper Knowlton observed Ward traveling about 55 mph and following another vehicle more closely than a reasonable and prudent distance.
Ward was less than one car length behind the vehicle in front, prompting the stop under R.C. 4511.34.
The trooper activated his cruiser's lights, and the video camera recorded approximately four seconds after activation; the video did not capture the actual close following.
After the stop, the trooper smelled alcohol and Ward was charged with operating a motor vehicle under the influence (R.C. 4511.19) and following too closely (R.C. 4511.34).
Ward moved to suppress the stop as lacking reasonable suspicion; the municipal court held hearings, reviewed videotape, and ultimately overruled the suppression motion.
Ward pled no contest to the R.C. 4511.19 violation and the R.C. 4511.34 charge was dismissed; he appeals the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by reasonable suspicion/probable cause	State contends Knowlton observed a R.C. 4511.34 violation and had at least reasonable suspicion to stop Ward.	Ward contends there was no valid basis to stop; the stop violated the Fourth Amendment.	Stop upheld; at least reasonable suspicion supported the stop.

Whren v. United States, 517 U.S. 806 (1996) (stops based on probable cause; objective reasonableness of the stop)
Mays, 119 Ohio St.3d 406 (2008) (probable cause not strictly required; reasonable suspicion suffices for stops)
Emerick, 2007-Ohio-4398 (Ohio App.) (limits on necessity of certainty for investigative stops)
Kelly, 188 Ohio App.3d 842 (2010-Ohio-3560) (one-car-length rule as indicator of violation of 4511.34)
Stokes, 2008-Ohio-5222 (Franklin App.) (one-car-length guideline used to infer probable cause/suspicion)
Meza, 2005-Ohio-1221 (Lucas App.) (prior cases support reasonable suspicion from following distance)