Mendenhall test (Ohio) · Go Syfert
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Mendenhall test in Ohio

8 Ohio opinions name it 2 courts 1989–2025 3 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.

Followed or applied (1)

CaseFollowedCited
State v. Finchergreen
ohioctapp · 1991 · cited in 1 Ohio opinions naming this issue, 1995–1995
2 sentences

1995For instance, in State v. Fincher (1991), 76 Ohio App.3d 721, 724-725 [ 603 N.E.2d 329, 331-332 ], the Cuyahoga County Court of Appeals found a seizure had occurred when police officers approached the appellant in a cruiser, exited the cruiser and approached within ten feet of the appellant, at which time the appellant dropped a pill bottle containing crack cocaine.

1995For instance, in State v. Fincher (1991), 76 Ohio App.3d 721, 724-725 [ 603 N.E.2d 329, 331-332 ], the Cuyahoga County Court of Appeals found a seizure had occurred when police officers approached the appellant in a cruiser, exited the cruiser and approached within ten feet of the appellant, at which time the appellant dropped a pill bottle containing crack cocaine.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Village of Linndale v. State green
ohio · 1999
2 sentences

2021There is no question that under the Mendenhall test, the local ordinances encompass the police power. “[T]he regulation of traffic is an exercise of police power that relates to public health and safety, as well as to the general welfare of the public.” Mendenhall at ¶ 19, citing Linndale v. State, 85 Ohio St.3d 52, 54 , 706 N.E.2d 1227 (1999).

2021There is no question that under the Mendenhall test, the local ordinances encompass the police power. “[T]he regulation of traffic is an exercise of police power that relates to public health and safety, as well as to the general welfare of the public.” Mendenhall at ¶ 19, citing Linndale v. State, 85 Ohio St.3d 52, 54 , 706 N.E.2d 1227 (1999).

22021–2021
State Ex Rel. Stanton v. Powell green
ohio · 1924
2 sentences

2025Stanton v. Powell, 109 Ohio St. 383 (1924); Beachwood v. Cuyahoga Cty.

2025Stanton v. Powell, 109 Ohio St. 383 (1924); Beachwood v. Cuyahoga Cty.

12025–2025
City of Canton v. State green
ohio · 2002
2 sentences

2021Id. at ¶ 17, citing Canton, 95 Ohio St.3d 149 , 766 N.E.2d 963 , at ¶ 9.

2021Id. at ¶ 17, citing Canton, 95 Ohio St.3d 149 , 766 N.E.2d 963 , at ¶ 9.

12021–2021
American Financial Services Ass'n v. City of Cleveland neutral
ohio · 2006
2 sentences

2017Assn. v. Cleveland, 112 Ohio St.3d 170 , 2006-Ohio-6043 , 858 N.E.2d 776 , ¶ 23. {¶20} The second step of the Mendenhall test is necessary only if the city ordinance involves an exercise of police power.

2017Assn. v. Cleveland, 112 Ohio St.3d 170 , 2006-Ohio-6043 , 858 N.E.2d 776 , ¶ 23. {¶20} The second step of the Mendenhall test is necessary only if the city ordinance involves an exercise of police power.

12017–2017
United States v. Cortez green
scotus · 1981
2 sentences

2003The totality of the circumstances approach "allows officers to draw on their own experience and specialized training to make inferences from and deductions about the cumulative information available to them that `might well elude an untrained person.'" Id. (quoting United States v. Cortez (1981), 449 U.S. 411 , 418 , 101 S.Ct. 690 , 66 L.Ed.2d 621 ). {¶ 18} Based upon the foregoing well-established principles of law, we agree with the trial court's conclusion that Trooper Mendenhall's stop of appellant's vehicle complied with the Fourth Amendment.

2003The totality of the circumstances approach "allows officers to draw on their own experience and specialized training to make inferences from and deductions about the cumulative information available to them that `might well elude an untrained person.'" Id. (quoting United States v. Cortez (1981), 449 U.S. 411 , 418 , 101 S.Ct. 690 , 66 L.Ed.2d 621 ). {¶ 18} Based upon the foregoing well-established principles of law, we agree with the trial court's conclusion that Trooper Mendenhall's stop of appellant's vehicle complied with the Fourth Amendment.

12003–2003
United States v. Arvizu green
scotus · 2002
1 sentence

2003The totality of the circumstances approach "allows officers to draw on their own experience and specialized training to make inferences from and deductions about the cumulative information available to them that `might well elude an untrained person.'" Id. (quoting United States v. Cortez (1981), 449 U.S. 411 , 418 , 101 S.Ct. 690 , 66 L.Ed.2d 621 ). {¶ 18} Based upon the foregoing well-established principles of law, we agree with the trial court's conclusion that Trooper Mendenhall's stop of appellant's vehicle complied with the Fourth Amendment.

12003–2003
United States v. Mendenhall green
scotus · 1980
2 sentences

1996Id. *486 A good argument may be made that a seizure occurred under the Mendenhall test when Officer Thomas activated the emergency lights of his cruiser as he approached Gonsior and his companions.

1996Id. *486 A good argument may be made that a seizure occurred under the Mendenhall test when Officer Thomas activated the emergency lights of his cruiser as he approached Gonsior and his companions.

11996–1996
State v. Nealen green
ohioctapp · 1992
2 sentences

1995“Additionally, the Cuyahoga County Court of Appeals found a seizure had occurred in State v. Nealen (1992), 84 Ohio App.3d 235 [ 616 N.E.2d 944 ], after applying the Mendenhall test.

1995“Additionally, the Cuyahoga County Court of Appeals found a seizure had occurred in State v. Nealen (1992), 84 Ohio App.3d 235 [ 616 N.E.2d 944 ], after applying the Mendenhall test.

11995–1995
Immigration & Naturalization Service v. Delgado green
scotus · 1984
2 sentences

1989In upholding the denial of Mendenhall’s motion to suppress, Justice Stewart reviewed these facts and stated: “[N]othing in the record suggests that the respondent had any objective reason to believe that she was not free to end the conversation in the concourse and proceed on her way, and for that reason we conclude that the agents’ initial approach to her was not a seizure.” 1 Id. at 555 .

1989The court also held that Mendenhall voluntarily consented to accompany the agents to the DEA office, id. at 558 , and she freely and voluntarily consented to the search of her person, id. at 559-560 .

11989–1989

Where else courts name it

IL 77 (1988–2023) WA 12 (1997–2019) PA 12 (1992–2018) TX 10 (1993–2022) CA 8 (1983–2021) OH 8 (1989–2025) VA 8 (1992–2012) WI 7 (2002–2024) MT 7 (1894–2024) TN 5 (1999–2019) NC 5 (1995–2018) MA 5 (2001–2015) NM 4 (2009–2015) FL 4 (2009–2012) LA 4 (1989–2009) MD 4 (1991–2019) NH 3 (1988–2004) MO 3 (1991–2016) DC 2 (1999–2019) HI 2 (1992–2011) NE 2 (1991–1992) CT 2 (1993–2008) KY 2 (2025–2026) WY 2 (1993–1994) ID 2 (1991–1995)

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.

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