State v. Williams, 2018 Ohio 5202

On Dec. 30, 2015, a convenience‑store clerk called 911 reporting a black car with tinted windows running in the store parking lot for over an hour; dispatcher sent Officers Rausch and Murphy.
Officers parked their cruiser bumper‑to‑bumper behind the car (blocking it), approached, knocked on the window, and when the driver began to roll the window up the officer extended a baton and ordered him to roll it back down; the driver identified himself as Jerome Williams.
Officers discovered Williams had active warrants, arrested him, and searched his vehicle, finding marijuana and a scale; while booking he was found to be concealing drugs internally.
Williams moved to suppress evidence seized after the stop; the trial court denied the motion, tried him in a bench trial, convicted him of tampering and drug possession offenses, and imposed costs.
On appeal the Sixth District reviewed whether the encounter was a seizure requiring reasonable, articulable suspicion and whether the officers had such suspicion; it also noted but did not decide a costs challenge because it reversed on suppression grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable, articulable suspicion to detain Williams (i.e., whether contact was a consensual encounter or a Terry stop)	State: citizen report of a running car in a higher‑crime area, tinted windows, late hour, and the driver’s rolling up the window justified detention and request for ID	Williams: the call reported only a person sitting in a parked, running car (not criminal activity); blocking the car and displaying a baton converted the contact into a seizure without reasonable suspicion	Court: No reasonable, articulable suspicion—the officers’ conduct amounted to a seizure and the totality of circumstances did not justify the stop; conviction vacated and case remanded
Whether trial court erred by failing to orally notify Williams in open court of imposed costs	Williams: trial court failed to notify him on the record of prosecution, supervision, confinement, assigned counsel costs, and statutory costs	State: R.C. 2947.23 requires imposition of prosecution costs and failure to orally notify is harmless; other cost issues preserved for appeal	Court: Not reached—issue was not decided because conviction was vacated on suppression grounds

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (investigative stop requires reasonable, articulable suspicion)
State v. Freeman, 64 Ohio St.2d 291 (Ohio 1980) (totality‑of‑circumstances test for reasonable suspicion)
State v. Bobo, 37 Ohio St.3d 177 (Ohio 1988) (presence in high‑crime area is a factor but not alone dispositive)
State v. Wallace, 145 Ohio App.3d 116 (Ohio Ct. App. 2001) (blocking a parked car and then discovering evidence—officer lacked reasonable suspicion before the seizure)
State v. Jackson, 89 N.E.3d 98 (Ohio Ct. App. 2017) (presence in a high‑crime area does not, by itself, supply reasonable suspicion)