State v. Jones - 2009-Ohio-316, 121 Ohio St. 3d 103, 902 N.E.2d 464

Rule:

A law-enforcement officer who personally observes a traffic violation while outside the officer's statutory territorial jurisdiction has probable cause to make a traffic stop; the stop is not unreasonable under the Fourth Amendment to the United States Constitution, U.S. Const. amend. IV.

Facts:

A police officer who responded to the scene of a vehicle accident was informed that one vehicle that was involved had left the scene. Based on information, the officer located the vehicle. He noted that the front end of the vehicle was smashed and the headlights were not on, and he stopped it. Upon questioning defendants, the driver, Adam Jones, and the passenger, Shawn Skropits, they indicated that they had weapons and that Jones did not have a license. Defendants were arrested and charged. Defendants’ suppression motion, based on their claim that the stop violated R.C. 2935.03 and U.S. Const. amend. IV, was denied by the trial court. They entered no contest pleas and were convicted and sentenced. The court of appeals reversed that determination, finding that there was neither reasonable suspicion nor probable cause to support the officer's stop.

Issue:

Under the circumstances, was there reasonable suspicion or probable cause to support the officer’s stop?

Answer:

Yes.

Conclusion:

The Court held that it was undisputed that there was a violation of § 2935.03(A)(1). However, the officer's observance of the vehicle operating at night without headlights constituted a statutory violation that provided probable cause to initiate the traffic stop. There was no amend. IV violation, such that suppression was improper in the circumstances. Accordingly, the Court reversed the judgments of the court of appeals and reinstated the trial court judgment.