State v. Cummins

Citations

• 2019 Ohio 1496

Syllabus

The trial court did not err by denying appellant's motion to suppress by rejecting appellant's claim that the trial court's finding of probable cause was improper where the state failed to prove what specific substance caused appellant's impairment. When determining whether there was sufficient probable cause to effectuate an arrest for operating a vehicle while under the influence of alcohol or drugs, the arresting officer need not conclusively identify what specific substance caused the offender's alleged impairment before an arrest can be made. The trial court also did not err by permitting a trooper to testify that she believed appellant was under the influence of marijuana given the trooper's education, training, and experience and inapplicability of the rules of evidence at a suppression hearing.