State v. Boles

Citations

• 158 N.E.3d 1013
• 2020 Ohio 4485

Syllabus

The State appeals from the trial court's decision granting appellee's motion to suppress evidence related to his operating a vehicle while under the influence of alcohol. The trial court erred both in finding the evidence insufficient to show that field sobriety tests administered to appellee substantially complied with National Highway Traffic Safety Administration (NHTSA) standards and in concluding that law enforcement officers lacked probable cause to arrest appellee. A deputy's uncontroverted testimony sufficed to establish substantial compliance with NHTSA standards, and testimony regarding appellee's vehicular collision, strong alcohol odor, glassy and bloodshot eyes, slurred speech, consumption of alcohol, and uneven gait demonstrated probable cause for arrest, even absent field sobriety test results. Judgment reversed and remanded.