Parma v. Coyne

Citations

• 2024 Ohio 3192

Syllabus

Motion to suppress Fourth Amendment investigatory stop \fruit of the poisonous tree\ reasonable suspicion reliable tip totality of the circumstances manifest weight. Judgment affirmed. A 9-1-1 caller's reliable tip that the defendant was belligerent, drunk, and threatening to be physically violent provided a sufficient basis to develop reasonable suspicion justifying the investigatory stop of defendant's vehicle. The evidence obtained after the stop, including the arresting officer's observations of the defendant's intoxication, the defendant's own admissions that he was drinking and should not be driving, and subsequent field sobriety tests, substantiated the reasonable suspicion arising from the 9-1-1 call, leading to the defendant's OVI arrest. Because reasonable suspicion justified the investigatory stop, the evidence gathered thereafter is not \fruit of the poisonous tree\ requiring suppression. Accordingly, we affirm the trial court denial of the defendant's motion to suppress.