State v. Ruhenkamp

Summary

The Ohio Second District Court of Appeals reversed Benjamin J. Ruhenkamp’s OVI and red-light violation convictions and remanded the matter for further proceedings. The court held that the traffic stop was unlawful because the officer lacked reasonable, articulable suspicion of a red-light violation when Ruhenkamp crossed the stop line while the signal was yellow, making the resulting OVI evidence subject to suppression as fruit of the poisonous tree.

Holdings

1. The traffic stop was unlawful because the officer lacked reasonable, articulable suspicion that Ruhenkamp had violated Ohio's red-light laws. Ruhenkamp crossed the stop line while the signal was yellow, and no red-light violation occurred.
2. Evidence of the OVI offense obtained as a result of the unlawful traffic stop was fruit of the poisonous tree and was subject to suppression.

Questions Presented

1. Whether the officer had reasonable, articulable suspicion to stop Ruhenkamp's vehicle for a suspected red-light violation when the vehicle crossed the stop line while the signal was yellow.
2. Whether evidence obtained after the traffic stop, including evidence of the OVI offense, was subject to suppression as fruit of the poisonous tree.

Disposition

reversed_and_remanded