State v. Spellacy

Citations

• 2019 Ohio 785

Syllabus

R.C. 4513.15 high-beam headlights suppression traffic stop oncoming approaching momentary flicker mistake of law objectively reasonable totality of the circumstances. The trial court erred in granting defendant's motion to suppress where the record demonstrated that the officer had an objectively reasonable belief based on the totality of the circumstances that a traffic violation occurred when the defendant flashed his high-beam headlights on two separate occasions while stopped at a traffic light. Even if the officer's belief was mistaken, an objectively reasonable mistake of law can constitute reasonable suspicion to justify the traffic stop.