State v. Brown

Summary

The Ohio First District Court of Appeals affirmed the Hamilton County Municipal Court’s suppression of evidence obtained after Maurice Brown’s vehicle was stopped and searched. The court held that the officer’s observations of Brown following another vehicle and looking toward a traffic stop, without additional specific and articulable facts connecting Brown to drug trafficking, amounted only to a hunch and did not establish reasonable suspicion for an investigatory stop.

Holdings

1. The officer lacked reasonable, articulable suspicion to stop Brown because the facts showed only that Brown was behind another vehicle, followed it from a location where a drug transaction had occurred, and appeared to look toward officers; those facts, without specific evidence that Brown was engaged in drug trafficking or counter-surveillance, amounted to an insufficient hunch.

Questions Presented

1. Whether the officer had a reasonable, articulable suspicion that Brown was engaged in criminal activity sufficient to justify the investigatory stop of his vehicle.
2. Whether the trial court properly granted Brown's motion to suppress evidence obtained after the stop, canine detention, and search.

Disposition

affirmed