The Supreme Court of Ohio has ruled that police were justified in detaining a woman leaning into a vehicle driven by a known drug trafficker, affirming the decision of the Fifth District Court of Appeals. The case involved Katrina Hale, who was detained outside a minivan at a convenience store after police suspected the driver, Terrance Cunningham, did not have a valid license. A search revealed illegal drugs, leading to multiple charges against Hale.
Justice Michael P. Donnelly wrote for the majority in the 6-1 decision, stating that all circumstances surrounding the stop must be considered. This included Cunningham's claim that Hale asked him to drive and her actions at the van window. "The purpose of the investigatory stop was for Detective Martens to confirm or dispel law enforcement’s reasonable suspicion," Justice Donnelly explained.
The trial court had initially suppressed evidence obtained from Hale, ruling there was no justification for her detention as she returned to the van from inside the store. However, this decision was overturned by the Fifth District Court of Appeals and affirmed by the Supreme Court.
Chief Justice Sharon L. Kennedy and Justices R. Patrick DeWine, Melody Stewart, Jennifer Brunner, and Joseph T. Deters supported Justice Donnelly's opinion.
In dissent, Justice Patrick F. Fischer argued that detaining Hale violated her Fourth Amendment rights since she was not committing any crime when returning to the store after reaching into the vehicle. He noted other courts do not allow officers to detain former passengers once a vehicle is parked.
Detective Benjamin Martens of the Licking County Sheriff’s Office detained Hale based on information from another officer about Cunningham's driving status and his own observations at the scene. During questioning, Hale admitted knowing Cunningham lacked a license but asked him to drive due to feeling ill.
Hale challenged her detention and subsequent search before trial but lost appeals up to Ohio's highest court. The Supreme Court found that Martens had reasonable suspicion based on circumstances indicating potential criminal activity involving both Cunningham and Hale.
Justice Fischer criticized this reasoning in his dissent: "Reaching into a vehicle and then returning to a convenience store is not a crime." He argued that Martens lacked sufficient cause for detaining Hale under constitutional standards without direct evidence of wrongdoing at that moment.