The Supreme Court of Ohio has ruled that a traffic stop, which led to the discovery of an unloaded firearm, was constitutional. The decision came after a Geauga County police officer asked a driver for his license upon realizing the vehicle owner with a suspended license was not driving.
Justice R. Patrick DeWine stated, "Under controlling United States Supreme Court precedent, an officer who has properly executed a traffic stop may make ordinary inquiries necessary to complete the mission of the traffic stop – including confirming that the driver has a valid driver’s license."
The court reversed an Eleventh District Court of Appeals decision, reinstating convictions against Jessica Dunlap and Je’Brel Lewis for improper handling of a firearm in their vehicle. Justices Patrick F. Fischer and Joseph T. Deters supported Justice DeWine's opinion based on a 2015 U.S. Supreme Court precedent.
Justice Michael P. Donnelly concurred in judgment only, suggesting narrower grounds using Ohio's 1997 State v. Robinette decision could resolve the case. Justice Melody Stewart also concurred in judgment only but emphasized state law requiring proof of licensure when asked by police.
Chief Justice Sharon L. Kennedy dissented, arguing that once it was clear Dunlap was not driving, there was no reason to question Lewis further. Justice Jennifer Brunner joined this dissent.
In 2021, Officer Andrew Centrackio stopped Dunlap's car after learning her license was suspended via the Law Enforcement Automated Data System (LEADS). Upon discovering Lewis driving instead, Centrackio asked for his license after Lewis provided suspicious answers about its validity.
Dunlap and Lewis sought to suppress evidence of the gun found during the stop, claiming it resulted from unlawful questioning about Lewis' driver's license status post-stop realization.
The court analyzed whether Officer Centrackio had grounds under the Fourth Amendment to ask for Lewis' license following a legal traffic stop initiated due to suspicion over Dunlap's suspended license status.
Justice Donnelly wrote that although Centrackio’s initial suspicion dissipated upon identifying Lewis as the driver, Lewis’ response warranted further inquiry into his licensure status under certain circumstances.
Chief Justice Kennedy maintained that extending stops without reasonable suspicion violated constitutional rights once initial suspicions were cleared.