State v. Wilds, 2021 Ohio 2554

On May 22, 2019, Johnny Wilds was stopped on Route 73/104 after Deputy Akers observed the Mustang he was driving go left of center twice; Trooper Lewis joined the stop.
Officers searched the vehicle (Wilds allegedly consented) and found a fake peanut-butter jar containing powder later tested as heroin mixed with fentanyl; $751 was forfeited as contraband.
Cellphone data recovered by a Cellbrite showed incoming/outgoing texts discussing drug use and oxycodone, some messages to/from Wilds.
Wilds was tried by jury on four felony counts (possession and trafficking in heroin and a fentanyl-related compound); convicted on all counts and sentenced to an aggregate 20–25½ years.
On appeal Wilds argued trial counsel was ineffective for failing to file a pretrial motion to suppress the traffic stop and ensuing evidence (invoking Turner re: fog line), claiming the stop was fabricated; the State argued probable cause existed because Wilds crossed the centerline.
The appellate court affirmed, holding counsel was not ineffective because Akers’ observation of crossing left of center provided a valid basis for the stop and there was no reasonable probability a suppression motion would have succeeded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for failing to file a motion to suppress the traffic stop and evidence	State: Turner (fog‑line rule) is inapplicable; officer observed crossing the centerline, giving probable cause for the stop, so no viable suppression motion existed	Wilds: Counsel should have moved to suppress; Turner shows minor lane contact insufficient; Akers gave only a legal conclusion about "left of center" and officers may have fabricated the stop	Court: Counsel was not ineffective. Crossing the centerline supported the stop; conspiracy/speculation would not likely have led to suppression, so no prejudice under Strickland

Strickland v. Washington, 466 U.S. 668 (establishes two‑part ineffective‑assistance standard: deficient performance and prejudice)
State v. Mays, 119 Ohio St.3d 406 (Ohio 2008) (traffic stop requires at least reasonable articulable suspicion or probable cause)
State v. Conway, 109 Ohio St.3d 412 (Ohio 2006) (explains prejudice standard under Strickland in Ohio criminal appeals)
State v. Brown, 115 Ohio St.3d 55 (Ohio 2007) (failure to file suppression motion is not per se ineffective assistance; defendant must show a basis for suppression)
State v. Nields, 93 Ohio St.3d 6 (Ohio 2001) (counsel’s failure to file suppression motion is ineffective only where motion had reasonable probability of success)
State v. Drummond, 111 Ohio St.3d 14 (Ohio 2006) (record must show a basis for suppression for ineffective‑assistance claim to succeed)