State v. Hall

Citations

• 2018 Ohio 2321
• 114 N.E.3d 730

Syllabus

The trial court did not err when it overruled appellant's motions to suppress. The record establishes that the police did not extend appellant's detention beyond what was reasonably necessary to resolve the issues associated with the traffic stop and to issue a traffic citation. The 19-minute time period between when the officer began writing the citation and when the K-9 unit alerted on appellant's vehicle was therefore reasonable under the facts presented in the instant case. The record establishes that the park ranger initiated the traffic stop of appellant after observing him run a stop sign located in an area which is adjacent to park grounds. Trial court did not err when it overruled appellant's motions to suppress regarding spontaneous statements he made before being arrested, as well as statements he made after waiving his rights pursuant to Miranda v. Arizona, 384 U.S. 436, 444, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). Trial court did not err when it overruled his motion to dismiss because appellant was unable to provide any evidence of \actual prejudice\ based upon a six-month delay between his arrest and the filing of his indictment. Pursuant to R.C. 1545.13(B), a park ranger has jurisdiction over criminal offenses committed on park grounds and on property adjacent to park grounds. The trial court did not abuse its discretion when it imposed a mandatory fine of $10,000.00 on appellant. Judgment affirmed.