State v. Wright, 2022 Ohio 2161

Officers responded twice to the Baymont Inn (noise/fight complaints). Earlier contact at ~1:17 a.m. involved room 408 occupants, including Wright.
At ~3:40 a.m., officers heard yelling and banging from an elevator coming to the lobby and suspected an altercation was occurring inside.
When the elevator opened, Wright and Olivia Harris exited; Harris appeared disheveled and out of breath, and Wright stood close to her between her and the doors.
Officers prevented Wright and Harris from leaving to investigate; Wright fled when an officer reached for him, was tackled outside the exit, and during the struggle a handgun was dislodged from him.
Wright denied ownership of the gun; he was later Mirandized. He moved to suppress the gun and his statements; the trial court denied suppression, he pled no contest, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable, articulable suspicion to detain Wright and Harris (Terry stop)	Sounds of an elevator altercation, Harris’s disheveled condition, proximity of Wright, and prior contact provided particularized suspicion	No individualized suspicion or report that Wright committed any crime; stop was unlawful	Stop was a lawful investigative detention under the totality of circumstances
Whether officers’ words/conduct in the lobby amounted to an arrest requiring probable cause	Officers merely temporarily detained them to investigate; no force displayed until Wright fled	The detention and commands constituted an arrest without probable cause	The encounter remained an investigative stop; not converted into an arrest before flight
Whether Wright’s pre-Miranda denials should be suppressed as involuntary or product of interrogation	Statements were voluntary, aimed at securing the scene, and not the product of interrogation	Statements were made while detained and before Miranda — should be suppressed	Denials admissible: voluntary, not the product of interrogation, and not prejudicial
Whether the handgun should be suppressed as fruit of an unlawful stop	Stop was lawful, so evidence is not tainted	If stop unlawful, the firearm is fruit of poisonous tree and should be suppressed	Firearm admissible because the stop and detention were lawful

Terry v. Ohio, 392 U.S. 1 (1968) (establishes investigative stop/reasonable-suspicion rule)
Miranda v. Arizona, 384 U.S. 436 (1966) (requires warnings before custodial interrogation)
Wong Sun v. United States, 371 U.S. 471 (1963) (fruit-of-the-poisonous-tree doctrine)
State v. Burnside, 797 N.E.2d 71 (Ohio 2003) (standard of appellate review for suppression hearings)
State v. Bobo, 524 N.E.2d 489 (Ohio 1988) (purpose of Terry stop: maintain status quo while officer investigates)
State v. Hairston, 126 N.E.3d 1132 (Ohio 2019) (display/use of force does not automatically convert stop to arrest)
State v. Hawkins, 140 N.E.3d 577 (Ohio 2019) (discussion of reasonable-suspicion standard and totality-of-circumstances analysis)