Background - Troopers observed a rental vehicle they thought suspicious; they stopped it for allegedly "following too closely" (R.C. 4511.34) after seeing it from a stationary position on the highway. - Dash‑camera video of the entire stop was admitted at the suppression hearing. - After the stop, officers searched the vehicle and discovered drugs hidden in the passenger seat void. - Woods moved to suppress the drug evidence; the trial court granted the motion, concluding the stop lacked probable cause. - The State timely appealed the suppression order under Crim.R. 12(K), certifying the appeal was not for delay and that suppression substantially weakened its case. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---:| | Was the traffic stop supported by probable cause for a non‑investigatory stop (R.C. 4511.34)? | Troopers had probable cause because Woods was following too closely given traffic conditions and other corroborating suspicious factors (rental, dust, fingerprints, "driverless" appearance). | Video and testimony showed congestion caused by lane changes (cop in left lane), reasonable braking by Woods, and no reliable evidence of following too closely. | Court affirmed suppression: competent, credible evidence (video) supported trial court finding no probable cause, so stop was unconstitutional. | ### Key Cases Cited Mapp v. Ohio, 367 U.S. 643 (Fourth Amendment applies to states) Delaware v. Prouse, 440 U.S. 648 (traffic stops are seizures under the Fourth Amendment) Terry v. Ohio, 392 U.S. 1 (reasonable suspicion standard for investigatory stops) Whren v. United States, 517 U.S. 806 (probable cause supports non‑investigatory traffic stops) Dayton v. Erickson, 76 Ohio St.3d 3 (Ohio standard: probable cause arises when officer witnesses traffic violation) State v. Burnside, 100 Ohio St.3d 152 (appellate review of mixed question: defer to trial court fact findings; apply law de novo) * Ornelas v. United States, 517 U.S. 690 (de novo review of legal application; give weight to inferences from local officers)