Background:

• Deputies in a marked cruiser observed a 2000 Plymouth Voyager drift left of center on Lancaster Road and followed it; dashcam did not capture the violation.
• Tags returned expired and registered owner’s license was suspended; deputies initiated a traffic stop.
• Passenger Jason Adams removed an item from his mouth that proved to be methamphetamine; all occupants were removed and Mirandized.
• A search of the van produced meth pipes, digital scales, and a black drawstring bag containing a quantity of methamphetamine that Worstell admitted was his and that he intended to sell.
• Worstell moved to suppress, arguing the stop lacked reasonable suspicion (darkness, cruiser position, dashcam gap); trial court denied the motion, noting deputy testimony credible and citing inevitable discovery due to impound/inventory possibilities.
• Worstell pleaded no contest; possession merged into trafficking; court imposed four years’ mandatory prison concurrent to a prior case. Appeal challenges lawfulness of the stop.

Issues:

Key Cases Cited

• State v. Burnside, 797 N.E.2d 71 (addresses mixed question appellate review of suppression findings)
• State v. Mays, 894 N.E.2d 1204 (Ohio Supreme Court: lane drift supports stop under reasonable and articulable suspicion)
• Ornelas v. United States, 517 U.S. 690 (establishes de novo review of legal application to suppression facts)
• Terry v. Ohio, 392 U.S. 1 (permissible investigative stops on reasonable suspicion)
• Whren v. United States, 517 U.S. 806 (probable cause justifies traffic stops; objective basis suffices)
• Dayton v. Erickson, 665 N.E.2d 1091 (Ohio: probable cause for traffic violation justifies stop)
• State v. Brinkley, 824 N.E.2d 959 (trial court credibility findings entitled to deference)
• State v. Fanning, 437 N.E.2d 583 (factfinder’s role in assessing witness credibility)