33 Ohio opinions name it 2 courts 2003–2026 10 in the last five years
The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Whren v. United Statesgreen2 sentences2007See United States v. Whren (1996), 517 U.S. 806 , 819 ; Dayton v. Erickson (1996), 76 Ohio St.3d 3 , syllabus. {¶ 13} Appellant has countered that the traffic stop was pretextual because Officer Rastorfer testified at the suppression hearing that he was not concerned about the turn signal and that he failed to issue a citation or a warning for the traffic violation. 2007See United States v. Whren (1996), 517 U.S. 806 , 819 ; Dayton v. Erickson (1996), 76 Ohio St.3d 3 , syllabus. {¶ 12} Appellant has countered that the traffic stop was pretextual because Officer Rastorfer testified at the suppression hearing that he was not concerned about the turn signal and that he failed to issue a citation or a warning for the traffic violation. | 2 | 2 |
City of Dayton v. Ericksongreen2 sentences2007See United States v. Whren (1996), 517 U.S. 806 , 819 ; Dayton v. Erickson (1996), 76 Ohio St.3d 3 , syllabus. {¶ 13} Appellant has countered that the traffic stop was pretextual because Officer Rastorfer testified at the suppression hearing that he was not concerned about the turn signal and that he failed to issue a citation or a warning for the traffic violation. 2007See United States v. Whren (1996), 517 U.S. 806 , 819 ; Dayton v. Erickson (1996), 76 Ohio St.3d 3 , syllabus. {¶ 12} Appellant has countered that the traffic stop was pretextual because Officer Rastorfer testified at the suppression hearing that he was not concerned about the turn signal and that he failed to issue a citation or a warning for the traffic violation. | 1 | 3 |
Illinois v. Caballesgreen2 sentences2021Id. at ¶ 13 quoting Illinois v. Caballes, 543 U.S. 405, 407 , 125 S.Ct. 834 , 160 L.Ed.2d 842 (2005). “‘When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.’” State v. Hall, 2d Dist. 2021Id. at ¶ 13 quoting Illinois v. Caballes, 543 U.S. 405, 407 , 125 S.Ct. 834 , 160 L.Ed.2d 842 (2005). “‘When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.’” State v. Hall, 2d Dist. | 1 | 2 |
State v. Robinettegreen2 sentences2017See State v. Robinette , 80 Ohio St.3d 234 , 685 N.E.2d 762 (1997). 2017See State v. Robinette , 80 Ohio St.3d 234 , 685 N.E.2d 762 (1997). | 1 | 2 |
State v. Johnsongreen1 sentence2026“The state does not have to charge a motorist with a traffic violation in order to use the facts of the traffic violation to support reasonable suspicion to initiate the traffic stop.” State v. Mihelarakis, 2004-Ohio-3047, ¶ 12 (7th Dist.); see also State v. Johnson, 2017-Ohio-8909, ¶ 16 (2d Dist.) (“Although the officer did not actually issue a speeding ticket, he witnessed [the defendant] driving in excess of the posted speed limit, satisfying the reasonable suspicion standard”); City of Marysville v. Creameans, 1992 WL 14357 , *2 (3d Dist. | 1 | 1 |
State v. Mihelarakis, Unpublished Decision (6-10-2004)green1 sentence2026“The state does not have to charge a motorist with a traffic violation in order to use the facts of the traffic violation to support reasonable suspicion to initiate the traffic stop.” State v. Mihelarakis, 2004-Ohio-3047, ¶ 12 (7th Dist.); see also State v. Johnson, 2017-Ohio-8909, ¶ 16 (2d Dist.) (“Although the officer did not actually issue a speeding ticket, he witnessed [the defendant] driving in excess of the posted speed limit, satisfying the reasonable suspicion standard”); City of Marysville v. Creameans, 1992 WL 14357 , *2 (3d Dist. | 1 | 1 |
State v. Reuschlinggreen1 sentence2025State v. Johnson, 2025-Ohio-890, ¶ 32 (11th Dist.) (“despite Officer Mehm’s testimony that he believed he had reasonable suspicion to extend the stop to await the canine officer, he also testified that he had not yet completed the traffic citation when Officer Merrifield arrived, and he had not delayed its completion”); State v. Reuschling, 2025-Ohio-516, ¶ 16 (11th Dist.) (“[t]he canine sniff was conducted upon completion of the field sobriety tests, and did not measurably prolong the stop, as the trooper had not yet issued a citation or warning for the window tint due to the intervening inve | 1 | 1 |
State v. Johnsongreen1 sentence2025State v. Johnson, 2025-Ohio-890, ¶ 32 (11th Dist.) (“despite Officer Mehm’s testimony that he believed he had reasonable suspicion to extend the stop to await the canine officer, he also testified that he had not yet completed the traffic citation when Officer Merrifield arrived, and he had not delayed its completion”); State v. Reuschling, 2025-Ohio-516, ¶ 16 (11th Dist.) (“[t]he canine sniff was conducted upon completion of the field sobriety tests, and did not measurably prolong the stop, as the trooper had not yet issued a citation or warning for the window tint due to the intervening inve | 1 | 1 |
State v. Flackgreen1 sentence2025See State v. Flack, 2023-Ohio-1705, ¶ 23 (3d Dist.). {¶16} The canine sniff was conducted upon completion of the field sobriety tests, and did not measurably prolong the stop, as the trooper had not yet issued a citation or warning for the window tint due to the intervening investigation for impairment. | 1 | 1 |
State v. Lozadagreen1 sentence2025“Typically, to conduct a pat-down search for weapons, an officer must have a ‘specific and articulable’ belief based on the ‘reasonably prudent man’ standard that an individual is armed and dangerous.” State v. Lozada, 92 Ohio St.3d 74, 75 (2001). | 1 | 1 |
State v. Caseygreen1 sentence2025Compare State v. Casey, 2014-Ohio-2586 (12th Dist.) (traffic stop unjustifiably prolonged past the period necessary to issue the citation after completing field sobriety tests). | 1 | 1 |
State v. Santiagogreen2 sentences2019We have said on numerous occasions that police officers in marked cruisers may stop vehicles for “ ‘any traffic violation no matter how slight, for the purpose of issuing a citation for the violation.’ ” State v. Santiago, 195 Ohio App.3d 649 , 2011-Ohio-5292 , 961 N.E.2d 264, ¶ 10 (2d Dist.), quoting Spillers at *2. {¶ 15} Here, the traffic stop was clearly valid, and Berry did not challenge the stop. 2019We have said on numerous occasions that police officers in marked cruisers may stop vehicles for “ ‘any traffic violation no matter how slight, for the purpose of issuing a citation for the violation.’ ” State v. Santiago, 195 Ohio App.3d 649 , 2011-Ohio-5292 , 961 N.E.2d 264, ¶ 10 (2d Dist.), quoting Spillers at *2. {¶ 15} Here, the traffic stop was clearly valid, and Berry did not challenge the stop. | 1 | 1 |
State v. Chagarisgreen2 sentences2016See State v. Chagaris, 107 Ohio App.3d 551 , 669 N.E.2d 92 (9th Dist.1995). 6 OHIO FIRST DISTRICT COURT OF APPEALS {¶16} A seizure justified solely by a traffic violation may become unlawful only if it is prolonged beyond the time that is reasonably required for the issuance of a citation for the violation. 2016See State v. Chagaris, 107 Ohio App.3d 551 , 669 N.E.2d 92 (9th Dist.1995). 6 OHIO FIRST DISTRICT COURT OF APPEALS {¶16} A seizure justified solely by a traffic violation may become unlawful only if it is prolonged beyond the time that is reasonably required for the issuance of a citation for the violation. | 1 | 1 |
| State v. Heldgreen | 1 | 1 |
| State v. Wellmangreen | 1 | 1 |
| State v. Johnson, L-06-1035 (8-3-2007)green | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Batchili
green
2 sentences2024“When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.” Id., citing State v. Batchili, 113 Ohio St.3d 403 , 2007-Ohio-2204 , 865 N.E.2d 1282, ¶ 12 . -4- “The reasonable stop time includes the amount of time it takes to conduct a computer check on the driver’s license, registration, and vehicle plates.” Id. 2024“When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.” Id., citing State v. Batchili, 113 Ohio St.3d 403 , 2007-Ohio-2204 , 865 N.E.2d 1282, ¶ 12 . -4- “The reasonable stop time includes the amount of time it takes to conduct a computer check on the driver’s license, registration, and vehicle plates.” Id. | 4 | 2016–2024 |
State v. Hall
green
2 sentences2021Darke, 2017-Ohio-2682 , 90 N.E.3d 276, ¶ 8 , quoting State v. Hill, 2d Dist. 2017Spinks testified that, after seeing the information about the passenger and "for the fact that Patrolman Maloney was already there, we would be able to run a sniff on the * * * car since it had only been several minutes." (Supp.Tr. at 14.) {¶ 34} Rather than writing a citation or warning, Spinks decided that he "was going to ask them for consent to search the vehicle." Officer Spinks re-approached Mee's vehicle and asked if anyone "had any drugs or anything illegal in the vehicle," and in response to a negative answer from Mee, "asked him if he would consent to a search to [sic] the vehicle." | 3 | 2017–2021 |
State v. Hill
green
2 sentences2019Montgomery No. 26345, 2016-Ohio-3087, ¶ 9 , citing State v. Batchili, 113 Ohio St.3d 403 , 2007-Ohio-2204 , 865 N.E.2d 1282, ¶ 12 . 2017Montgomery No. 26345, 2016-Ohio-3087, ¶ 9 , citing State v. Batchili, 113 Ohio St.3d 403 , 2007-Ohio-2204 , 865 N.E .2d 1282, ¶ 12. | 2 | 2017–2019 |
State v. Carlson
green
2 sentences2004This traffic violation provided probable cause for the deputy to stop and detain the vehicle for the purpose of issuing a warning or a citation for that violation. {¶ 13} "When a law enforcement officer stops a vehicle for a traffic violation, the officer may detain the motorist for a period of time sufficient to issue the motorist a citation and to perform routine procedures such as a computer check on the motorist's driver's license, registration and vehicle plates. `In determining if an officer completed these tasks within a reasonable length of time, the court must evaluate the duration of 2004This traffic violation provided probable cause for the deputy to stop and detain the vehicle for the purpose of issuing a warning or a citation for that violation. {¶ 13} "When a law enforcement officer stops a vehicle for a traffic violation, the officer may detain the motorist for a period of time sufficient to issue the motorist a citation and to perform routine procedures such as a computer check on the motorist's driver's license, registration and vehicle plates. `In determining if an officer completed these tasks within a reasonable length of time, the court must evaluate the duration of | 2 | 2004–2004 |
State v. Lansing
neutral
1 sentence2025Batchili at ¶ 14. [Cite as State v. Lansing, 2025-Ohio-1241 .] {¶40} In addition, appellant cites State v. Landers, 2007-Ohio- 7146 (10th Dist.) in support. | 1 | 2025–2025 |
In Re Oliver
green
2 sentences2025Golub claims that under In re Oliver, 333 U.S. 257 (1948), the probate court’s failure to give “notice of the accusation” prior to the citation hearing violated his due-process rights. 2025Golub claims that under In re Oliver, 333 U.S. 257 (1948), the probate court’s failure to give “notice of the accusation” prior to the citation hearing violated his due-process rights. | 1 | 2025–2025 |
State v. Bobo
green
1 sentence2025State v. Johnson, 2025-Ohio-890, ¶ 32 (11th Dist.) (“despite Officer Mehm’s testimony that he believed he had reasonable suspicion to extend the stop to await the canine officer, he also testified that he had not yet completed the traffic citation when Officer Merrifield arrived, and he had not delayed its completion”); State v. Reuschling, 2025-Ohio-516, ¶ 16 (11th Dist.) (“[t]he canine sniff was conducted upon completion of the field sobriety tests, and did not measurably prolong the stop, as the trooper had not yet issued a citation or warning for the window tint due to the intervening inve | 1 | 2025–2025 |
State v. Hairston (Slip Opinion)
green
1 sentence2025State v. Johnson, 2025-Ohio-890, ¶ 32 (11th Dist.) (“despite Officer Mehm’s testimony that he believed he had reasonable suspicion to extend the stop to await the canine officer, he also testified that he had not yet completed the traffic citation when Officer Merrifield arrived, and he had not delayed its completion”); State v. Reuschling, 2025-Ohio-516, ¶ 16 (11th Dist.) (“[t]he canine sniff was conducted upon completion of the field sobriety tests, and did not measurably prolong the stop, as the trooper had not yet issued a citation or warning for the window tint due to the intervening inve | 1 | 2025–2025 |
Florida v. Royer
green
1 sentence2024“When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.” Id., citing State v. Batchili, 113 Ohio St.3d 403 , 2007-Ohio-2204 , 865 N.E.2d 1282, ¶ 12 . -4- “The reasonable stop time includes the amount of time it takes to conduct a computer check on the driver’s license, registration, and vehicle plates.” Id. | 1 | 2024–2024 |
Cleveland v. Whitmore, Unpublished Decision (8-25-2005)
neutral
1 sentence2023Id. at ¶ 20 – 22. {¶ 20} In Cleveland v. Go Invest Wisely, LLC, 8th Dist. | 1 | 2023–2023 |
Newburgh Hts. v. State
green
2 sentences2022SLIP OPINION NO. 2022-OHIO-1642 THE VILLAGE OF NEWBURGH HEIGHTS, ET AL., APPELLEES, v. THE STATE OF OHIO, APPELLANT. [Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as Newburgh Hts. v. State, Slip Opinion No. 2022-Ohio-1642 .] Home rule—Ohio Constitution, Article XVIII, Section 3—R.C. 5747.502—No conflict exists between a municipality’s ordinance allowing the use of traffic cameras and state law allowing a reduction of a municipality’s share of the state’s local-government funds—R.C. 4511.099—No conflict exists between a municipality’s ordinance allowin 2022SLIP OPINION NO. 2022-OHIO-1642 THE VILLAGE OF NEWBURGH HEIGHTS, ET AL., APPELLEES, v. THE STATE OF OHIO, APPELLANT. [Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as Newburgh Hts. v. State, Slip Opinion No. 2022-Ohio-1642 .] Home rule—Ohio Constitution, Article XVIII, Section 3—R.C. 5747.502—No conflict exists between a municipality’s ordinance allowing the use of traffic cameras and state law allowing a reduction of a municipality’s share of the state’s local-government funds—R.C. 4511.099—No conflict exists between a municipality’s ordinance allowin | 1 | 2022–2022 |
Newburgh Hts. v. State
green
2 sentences2022(No. 2021-0247—Submitted February 9, 2022—Decided May 19, 2022.) APPEAL from the Court of Appeals for Cuyahoga County, SUPREME COURT OF OHIO Nos. 109106 and 109114, 2021-Ohio-61 . ________________ KENNEDY, J. {¶ 1} In this discretionary appeal from a judgment of the Eighth District Court of Appeals, we are asked to decide whether the Ohio Constitution’s Home Rule Amendment, Article XVIII, Section 3, prohibits the General Assembly from enacting statutes that (1) reduce a municipality’s share of the state’s local- government fund by an amount equal to the fines collected based on citations arisi 2022(No. 2021-0247—Submitted February 9, 2022—Decided May 19, 2022.) APPEAL from the Court of Appeals for Cuyahoga County, SUPREME COURT OF OHIO Nos. 109106 and 109114, 2021-Ohio-61 . ________________ KENNEDY, J. {¶ 1} In this discretionary appeal from a judgment of the Eighth District Court of Appeals, we are asked to decide whether the Ohio Constitution’s Home Rule Amendment, Article XVIII, Section 3, prohibits the General Assembly from enacting statutes that (1) reduce a municipality’s share of the state’s local- government fund by an amount equal to the fines collected based on citations arisi | 1 | 2022–2022 |
United States v. Jacobsen
green
1 sentence2020For example, “[a] seizure that is justified solely by the interest in issuing a * * * ticket -7- Case No. 14-19-25 to the driver can become unlawful if it is prolonged beyond the time reasonably required to complete that mission.” Id. {¶14} “‘When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.’” State v. Hall, 2d Dist. | 1 | 2020–2020 |
Ornelas v. United States
green
2 sentences2019Fairfield No. 14-CA-13, 2014-Ohio-5027, ¶ 14 , citing Ornelas v. United States, 517 U.S. 690 , 116 S.Ct. 1657 , 134 L.Ed.2d 911 (1996). -6- {¶ 15} “When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.” State v. Hill, 2d Dist. 2019Fairfield No. 14-CA-13, 2014-Ohio-5027, ¶ 14 , citing Ornelas v. United States, 517 U.S. 690 , 116 S.Ct. 1657 , 134 L.Ed.2d 911 (1996). -6- {¶ 15} “When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.” State v. Hill, 2d Dist. | 1 | 2019–2019 |
State v. Gordon
green
1 sentence2019Fairfield No. 14-CA-13, 2014-Ohio-5027, ¶ 14 , citing Ornelas v. United States, 517 U.S. 690 , 116 S.Ct. 1657 , 134 L.Ed.2d 911 (1996). -6- {¶ 15} “When an officer detains a motorist for a traffic violation, the stop should delay the motorist only for the amount of time necessary to issue a citation or warning.” State v. Hill, 2d Dist. | 1 | 2019–2019 |
E & R Erectors, Inc. v. Secretary of Labor
green
1 sentence2018Id. at 160 . | 1 | 2018–2018 |
State v. Moore
green
2 sentences2018To the 6 extent that Anderson argues Distelrath continued the detention “without issuing a citation or warning,” Distelrath testified at the suppression hearing that a written warning was issued to Anderson. {¶20} Anderson also argues that, even if the stop was proper, the presence of marijuana shake alone did not provide probable cause to search his vehicle. {¶21} Generally, for a search to be reasonable under the Fourth Amendment, “it must be based upon probable cause and executed pursuant to a warrant.” State v. Moore, 90 Ohio St.3d 47, 49 , 734 N.E.2d 804 (2000). 2018To the 6 extent that Anderson argues Distelrath continued the detention “without issuing a citation or warning,” Distelrath testified at the suppression hearing that a written warning was issued to Anderson. {¶20} Anderson also argues that, even if the stop was proper, the presence of marijuana shake alone did not provide probable cause to search his vehicle. {¶21} Generally, for a search to be reasonable under the Fourth Amendment, “it must be based upon probable cause and executed pursuant to a warrant.” State v. Moore, 90 Ohio St.3d 47, 49 , 734 N.E.2d 804 (2000). | 1 | 2018–2018 |
| State v. Colby, Unpublished Decision (1-16-2004) neutral | 1 | 2016–2016 |
| Steinfels v. Ohio Department of Commerce, Division of Securities green | 1 | 2013–2013 |
| Chirila v. Ohio State Chiropractic Board green | 1 | 2013–2013 |
| State v. Buckner, 21892 (8-24-2007) green | 1 | 2012–2012 |
| United States v. Place green | 1 | 2008–2008 |
| City of Columbus v. Anderson green | 1 | 2006–2006 |
| City of Columbus v. Truax green | 1 | 2006–2006 |
| United Food & Commercial Workers Union, Local 1059 v. Pillsbury Co. green | 1 | 2003–2003 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.