State v. Hein

Citations

• 2023 Ohio 1592

Syllabus

State's appeal. The trial court erred in granting appellee's motion to suppress evidence. The court made no factual findings to which an appellate court could defer and also erroneously held the State to a probable cause standard for investigatory detention. The State was only required to demonstrate that the police had a reasonable, articulable suspicion of criminal activity. Furthermore, evidence elicited during the suppression hearing revealed that the police did have reasonable, articulable suspicion to detain appellee and to administer a field sobriety test. The test was administered in substantial compliance with applicable standards, and it indicated that appellee was intoxicated. Finally, even without the sobriety test results, the police had probable cause to arrest appellee based on the totality of the circumstances. Judgment reversed and remanded.