Lakewood v. Tittl

CourtOhio Court of Appeals
DecidedJune 25, 2026
Docket115701
StatusPublished

This text of Lakewood v. Tittl (Lakewood v. Tittl) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lakewood v. Tittl, (Ohio Ct. App. 2026).

Opinion

[Cite as Lakewood v. Tittl, 2026-Ohio-2413.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

CITY OF LAKEWOOD, :

Plaintiff-Appellee, : No. 115701 v. :

JULIE TITTL, :

Defendant-Appellant. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: June 25, 2026

Criminal Appeal from the Lakewood Municipal Court Case No. TRC 2501218

Appearances:

Myriam A. Miranda, Lakewood Prosecuting Attorney, and Andrew N. Fleck, Assistant Prosecuting Attorney, for appellee.

Cullen Sweeney, Cuyahoga County Public Defender, and Erika B. Cunliffe, Assistant Public Defender, for appellant.

EILEEN T. GALLAGHER, P.J.:

Defendant-appellant Julie Tittl appeals her conviction for one count of

operating a vehicle while under the influence of alcohol or drugs (“OVI”). She claims

the following errors: 1. The trial court erred in denying Julie Tittl’s motion to suppress the results of the field[-]sobriety tests.

2. The trial court erred in excluding the notarized letter from Julie Tittl’s physical therapist from the evidence considered at the suppression hearing.

3. Julie Tittl’s OVI conviction is against the manifest weight of the evidence.

We find that the motion to suppress was properly denied, that the

notarized letter from Tittl’s physical therapist was properly excluded, and that Tittl’s

OVI conviction is not against the manifest weight of the evidence. Accordingly, we

affirm the trial court’s judgment.

I. Facts and Procedural History

On March 17, 2025, Tittl was arrested and charged with OVI and failure

to control her vehicle. Prior to trial, the city prosecutor placed a plea offer on the

record. Because Tittl was a first-time offender and there was no accident, plaintiff-

appellee City of Lakewood (“Lakewood” or “City”) offered to resolve the entire case

in exchange for a guilty or no-contest plea to either physical control, a first-degree

misdemeanor that carries no points on a driver’s license, or reckless operation, a

second-degree misdemeanor with no mandatory suspensions but carries a four-

point violation. Tittl rejected the plea offer.

Tittl later filed a motion to suppress evidence of the field-sobriety tests

administered to her at the time of her arrest on grounds that the officer who

conducted the tests failed to comply with the standards outlined in the National

Highway Traffic Safety Administration (“NHTSA”) manual. By agreement of the parties, the court held a hearing on the motion to suppress simultaneously with a

bench trial on the charges.

Stacy Hubert-Bash (“Hubert-Bash”) testified that on the evening of

March 17, 2025, she observed an SUV “swerving across the line . . . back and forth.”

(Tr. 43.)1 She was “terrified” that the driver, later identified as Tittl, would hurt

herself or others, and she called 911. (Tr. 43-44.) She explained:

I honestly was terrified for them. If you were to listen to the 911 call, you would hear me . . . . I was just like, “Oh, my gosh. Oh, my gosh. Please, you guys have got to get here because I don’t know if something is wrong with the driver.”

So I was terrified.

(Tr. 45.) Hubert-Bash followed Tittl’s vehicle while she was talking to the 911

dispatcher, and she observed Tittl’s SUV stop suddenly. (Tr. 44.) By then, the police

had arrived on the scene, and Hubert-Bash went home.

Officer Raymond Halas (“Halas”) testified that he responded to a

complaint of a possibly intoxicated driver on the evening of March 17, 2025. When

he arrived on the scene, he observed Tittl’s SUV “swerving all over its lane going

eastbound.” (Tr. 59.) He explained:

As I was getting close to that vehicle . . . the vehicle . . . swerved right out of its lane of travel, through a bunch of salt debris and everything on the road in a lane that was not for vehicular travel, struck the curb, and came to an abrupt stop with both passengers’ tires up on top of the curb near the sidewalk.

(Tr. 60.)

1 All the citations to the transcript refer to the transcript of the trial held on

September 24, 2025. Halas testified that he could smell alcohol emanating from Tittl’s car

and that the odor became stronger when she began talking. (Tr. 62.) Halas was

wearing a body camera that recorded his interactions with Tittl, and the body-

camera video was entered into evidence as the City’s exhibit No. 3. Halas asked Tittl

why she left her lane of travel, and she replied that she was waiting for someone to

give her instructions from the Gold Coast, an area on Lake Avenue. (Tr. 62; City

exhibit No. 3.) They were stopped on Detroit Avenue in Lakewood, and Tittl

repeatedly pointed to Lakewood City Hall when she was referring to the Gold Coast,

but the Gold Coast bears no resemblance to City Hall. (Tr. 63; City exhibit No. 3.)

Officer Halas asked Tittl what street they were on, and she told him they were on

Clifton Boulevard when they were actually on Detroit Avenue. (Tr. 63; City exhibit

No. 3.) Tittl has lived in Lakewood for 20 years and would likely have been familiar

with the city’s main streets. (Tr. 112.)

Tittl told Halas that she was coming from the gym, which she identified

as Planet Fitness in Lakewood, but Planet Fitness did not exist in Lakewood at that

time. (Tr. 75.) Halas testified that Tittl was not dressed in “gym-style attire” and

that she was wearing jeans, a sweatshirt, and a beaded shamrock necklace. (Tr. 75.)

Following their brief conversation, Officer Halas asked Tittl to perform

three field-sobriety tests. Before administering the tests, Halas asked Tittl if she had

medical conditions that would limit her ability to perform the tests properly.

(Tr. 65-66.) Tittl reported that she had Graves’ disease, POTS, and long Covid.

(Tr. 65.) According to Halas, Tittl was uncooperative and was unable to follow

his instructions. He repeated the instructions for the horizontal gaze nystagmus

(“HGN”) test multiple times, and she eventually completed it. In doing so, Halas

observed a “lack of smooth pursuit in both eyes,” “nystagmus prior to 45 degrees in

both eyes,” and “sustained nystagmus at maximum deviation,” which indicated six

clues of impairment. (Tr. 66-71.)

Halas next administered the walk and turn (“WAT”) test. As with the

HGN test, Halas had to explain the instructions several times before Tittl could

complete the test. While Tittl performed the test, Halas observed “seven” of “eight”

possible clues of impairment. (Tr. 71.) He explained that Tittl (1) was unable to

stand in a starting position, (2) stepped off the line, (3) did not touch heel to toe, (4)

took the incorrect number of steps despite repeated instructions, and (5) turned

incorrectly before stopping completely. (Tr. 70-71.)

Finally, Halas administered the one-leg stand (“OLS”) test. During

Tittl’s performance of the OLS test, Halas observed three of four possible clues of

impairment. (Tr. 72.) She swayed during the test, used her arms for balance, and

put her foot down before the end of the 30-second time requirement. (Tr. 72; City

exhibit No. 3.) Based on “the totality of the circumstances,” including Tittl’s driving

behavior, the odor of alcohol, her inability to follow instructions, and her

performance on the field-sobriety tests, Halas arrested her for OVI. (Tr. 72-73.)

Upon reaching the Lakewood police station, Halas offered Tittl the

opportunity to take a breath test. (Tr.

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Lakewood v. Tittl, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lakewood-v-tittl-ohioctapp-2026.