State v. Woody, 2016 Ohio 631

Sgt. Murphy followed Woody after receiving a dispatch about a potentially intoxicated driver on Rt. 58 in Amherst, observing weaving in Woody’s lane before stopping him.
Woody was identified as the driver; a strong odor of alcohol and field sobriety tests followed the stop.
Woody was arrested for operating a vehicle under the influence of alcohol; charges included DUI, prohibited BAC, and weaving.
Woody moved to suppress the stop; the Oberlin Municipal Court denied the suppression motion.
Woody pled no contest to DUI (A1) as a second offense, and the court sentenced 180 days in jail with 150 suspended; the appeal challenges suppression and sentence as to legality.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was based on reasonable suspicion	Woody: no reasonable suspicion.	State: tip from identified citizen plus observed weaving supported stop.	Stop upheld; reasonable suspicion found.
Whether the tip from an identified citizen informant justified the stop	Woody: tip lacked sufficient reliability.	State: identified citizen informant provides reliable basis for stop.	Tip reliability sufficient; stop valid.
Whether the sentence exceeded the mandatory minimum and abused discretion	Woody: sentence above minimum; factors not considered.	State: sentence within statutory range; 2929.22 factors reviewed.	Sentence within the allowed range; no abuse of discretion.

State v. Burnside, 100 Ohio St.3d 152 (2003) (standard for evaluating suppression rulings; mixed law and fact review)
Maumee v. Weisner, 87 Ohio St.3d 295 (1999) (circumstances-based reasonable suspicion; dispatch reliability considerations)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances approach for reliability of tips)
United States v. Cortez, 449 U.S. 411 (1981) (informant tip reliability and corroboration in stop analysis)
Alabama v. White, 496 U.S. 325 (1990) (anonymous vs identified informants; reliability considerations)