State v. Williams-Stupp
2025 Ohio 1815
Ohio Ct. App.2025Background
- Tion Williams-Stupp was indicted in Montgomery County, Ohio on one count of carrying a concealed weapon (4th-degree felony) and one count of violating a protection order (1st-degree misdemeanor).
- The charges stemmed from a May 8, 2024, police encounter in which Williams-Stupp was stopped after surveillance officers observed him allegedly jaywalking in a high-crime area; a gun was recovered.
- Williams-Stupp moved to suppress evidence, arguing the stop lacked reasonable suspicion because he did not jaywalk.
- At the initial suppression hearing, Detective Phillips testified about Williams-Stupp’s conduct based partly on statements from Detective Orndorff.
- After defense arguments highlighted reliance on hearsay, the trial court sua sponte reopened the suppression hearing to allow Detective Orndorff to testify directly, giving both parties an opportunity for examination.
- The trial court ultimately denied the motion to suppress, Williams-Stupp entered no contest pleas, and appealed the conviction on grounds including the suppression ruling and the procedure followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by reopening the suppression hearing and calling an additional witness. | The court lost its impartiality and aided prosecution by calling a witness after briefing was complete. | The court acted within its discretion to ensure a full and fair hearing, without acting as a prosecutor. | No abuse of discretion; the court acted to ensure thorough fact-finding, not to advocate for a party. |
| Whether the trial court erred by denying the motion to suppress based on the investigatory stop. | Officers lacked reasonable suspicion; initial testimony was unreliable hearsay, and evidence insufficient. | The stop was based on collective officer observations and reliable communication of a jaywalking violation. | The stop was justified by reasonable suspicion based on credible, direct testimony of jaywalking by an officer. |
| Whether admitting hearsay at a suppression hearing was error. | Detective's testimony about another officer’s observations was unreliable and inadmissible hearsay. | Suppression hearings allow hearsay; collective knowledge doctrine applies; defense eventually cross-examined. | Hearsay allowed in suppression hearings; defense was afforded opportunity to challenge through cross-examination. |
| Whether police observations amounted to a jaywalking violation justifying the stop. | Phillips’s observations didn’t show jaywalking; Orndorff’s report was lacking detail and reliability. | Orndorff saw Williams-Stupp walking in the street instead of on parallel sidewalks, violating ordinance. | Orndorff’s firsthand, credible account supported reasonable suspicion for jaywalking under local ordinance. |
Key Cases Cited
- State v. Adams, 62 Ohio St.2d 151 (reaffirming judicial neutrality when calling witnesses under Evid.R. 614)
- State v. Henderson, 51 Ohio St.3d 54 (collective knowledge doctrine supports stops based on radio communications)
- Terry v. Ohio, 392 U.S. 1 (establishing standard for investigatory stops under the Fourth Amendment)
- Florida v. Jimeno, 500 U.S. 248 (reasonableness as the core of Fourth Amendment analysis)
- Katz v. United States, 389 U.S. 347 (defining scope of Fourth Amendment protections)