State v. Sargent

Summary

The Ohio Seventh District Court of Appeals affirmed the Mahoning County Court of Common Pleas judgment granting Chad Sargent’s motion to suppress evidence obtained after a traffic stop. The court held that the State failed to establish a valid basis for the stop under Ohio Revised Code section 4513.05(A) or reasonable, articulable suspicion of criminal activity.

Holdings

1. The State failed to establish a credible traffic violation because the record did not show that Sargent’s rear license plate was not illuminated and legible from 50 feet as required by R.C. 4513.05(A).
2. The State failed to demonstrate reasonable, articulable suspicion that criminal activity had occurred to justify the traffic stop.
3. The trial court did not err in granting Sargent’s motion to suppress.

Questions Presented

1. Whether the trial court applied the correct standard in reviewing the traffic stop.
2. Whether the State established probable cause or reasonable, articulable suspicion to justify the stop for an alleged violation of R.C. 4513.05(A).
3. Whether the trial court properly granted Sargent’s motion to suppress.

Disposition

affirmed