Lakewood v. Tittl

Citations

• 2026 Ohio 2413

Syllabus

Operating a vehicle while under the influence of alcohol or drugs (\OVI\); motion to suppress; field-sobriety tests; substantial compliance; horizontal gaze nystagmus test; walk and turn test; one-leg stand test; hearsay; abuse of discretion; manifest weight of the evidence. Officer's testimony regarding defendant's performance on field-sobriety tests was admissible where evidence showed the officer substantially complied with the requirements outlined in the National Highway Traffic Safety Administration (\NHTSA\) manual for administering field-sobriety tests. Exclusion of a notarized letter from defendant's physical therapist from the evidence was not an abuse of discretion where the letter was hearsay and would likely have been duplicative of other evidence. Defendant's conviction was not against the manifest weight of the evidence.