DRIVER STOPPED BY POLICE WITHOUT COMMITTING A TRAFFIC VIOLATION
Defendant was stopped by a Springfield Township police officer and charged with driving under an OVI suspension under R.C. 4510.14. The vehicle she was driving was registered in her daughter’s name, and the officer did not cite her for any traffic violations other than the OVI suspension.
Her attorney filed a motion to suppress, arguing that the officer had no legal basis to stop her vehicle in the first place. At the suppression hearing, the officer admitted that he could not recall the reason for the stop. He offered only vague testimony, stating he “believed” he stopped the vehicle but could not remember why.
Despite this, the trial court denied the motion to suppress, and she was convicted after a bench trial. She appealed.
LEGAL ISSUES ON APPEAL
Two major issues were raised on appeal:
- Did Defendant meet her initial burden on the motion to suppress by showing a warrantless seizure (that she was stopped without probable cause)?
- Did the State meet its burden of proving that the stop was lawful, based on reasonable suspicion or probable cause?
THE COURT'S DECISION: THE STOP WAS UNCONSTITUTIONAL
The appellate court sided with Defendant.
- The court explained that under Xenia v. Wallace, once a defendant shows that a warrantless stop occurred, the burden shifts to the State to prove the stop was justified.
- Defendant met her burden by alleging and showing that the officer stopped her without citing any other violation.
- The State then failed to meet its burden because the officer could not recall any specific reason for the stop and offered no articulable facts to support it.
Because the State could not justify the stop, the court held that the traffic stop was unconstitutional. The trial court’s denial of the motion to suppress was reversed, and the case was sent back with instructions to grant the suppression motion.
WHY THIS CASE MATTERS
This case is an important reminder for anyone charged with OVI or driving under an OVI suspension in Ohio:
FIRST: Police must have a lawful reason to stop your vehicle. A vague recollection or “belief” is not enough.
SECOND: If the stop itself is unconstitutional, all evidence that comes after may be thrown out.
THIRD: Filing a motion to suppress can be a powerful tool in defending OVI and license suspension cases.
TAKEAWAY
In State v. Watts, the Ohio Court of Appeals reinforced a critical point: traffic stops require specific, articulable facts to justify them. Without that, the stop is unlawful and the case can collapse. If you have been charged with OVI, DUI, or driving under an OVI suspension in Ohio, it’s important to have an experienced DUI lawyer review the stop and evaluate whether a motion to suppress could apply in your case.
