State v. Williamson
2017 Ohio 7363
| Ohio Ct. App. | 2017Background
- Williamson was stopped by a state trooper for alleged marked-lanes violations on SR 281 in Defiance County.
- The trooper detected expired vehicle registration and Williamson refused chemical testing after arrest.
- Williamson was charged with OVI, expired registration, and a minor marked-lanes violation in TRC1605231.
- An administrative license suspension (ALS) was issued following Williamson’s refusal to submit to chemical testing.
- Williamson moved to suppress evidence on the basis that the trooper lacked reasonable suspicion for a marked-lanes stop; ALS appeal followed the suppression motion.
- The trial court denied the suppression motion and denied the ALS appeal; Williamson pleaded no contest to OVI under a plea agreement and the court sentenced accordingly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was reasonable suspicion to stop Williamson. | Williamson argues Gardner lacked reasonable suspicion for a marked-lanes stop. | State contends the stop was valid based on observed lane deviations and safety concerns. | Stop deemed valid; suppression denied. |
Key Cases Cited
- State v. Burnside, 100 Ohio St.3d 152 (2003-Ohio-5372) (standard for suppression review; fact-finder credibility)
- State v. Carter, 72 Ohio St.3d 545 (1995) (mixed questions of fact and law; suppression deference to trial court)
- State v. Moore, 2008-Ohio-2407 (3d Dist. Marion No. 9-07-60) (reasonable suspicion under 4511.33 analyzed)
- State v. Andrews, 57 Ohio St.3d 86 (1991) (probative theories of reasonable suspicion and safety concerns)
- State v. Chatton, 11 Ohio St.3d 59 (1984) (lane deviation and safety considerations for stops)