State v. Arnold

2026 Ohio 998
CourtOhio Court of Appeals
DecidedMarch 19, 2026
Docket25CA24
StatusPublished

This text of 2026 Ohio 998 (State v. Arnold) 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
State v. Arnold, 2026 Ohio 998 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Arnold, 2026-Ohio-998.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT ROSS COUNTY

State of Ohio, : Case No. 25CA24

Plaintiff-Appellee, : DECISION AND JUDGMENT ENTRY v. :

Misty Lynn Arnold, : RELEASED 3/19/2026

Defendant-Appellant. :

______________________________________________________________________ APPEARANCES:

Katherine Ross-Kinzie, Supervising Attorney, Appeals and Postconviction Department, Office of the Ohio Public Defender, Columbus, Ohio, for appellant.

Andrew Anastasi, Assistant Law Director, Chillicothe, Ohio, for appellee. ______________________________________________________________________ Hess, J.

{¶1} Misty Lynn Arnold appeals from a judgment of the Chillicothe Municipal

Court convicting her, following a no contest plea, of operating a vehicle under the

influence of alcohol, a drug of abuse, or a combination of them (“OVI”). Arnold presents

one assignment of error asserting that the trial court erred by denying her motion to

suppress evidence that was discovered from an unlawful traffic stop. For the reasons

which follow, we overrule the assignment of error and affirm the trial court’s judgment.

I. FACTS AND PROCEDURAL HISTORY

{¶2} In January 2025, Arnold was cited for OVI in violation of R.C.

4511.19(A)(1)(a), OVI in violation of R.C. 4511.19(A)(2), driving under financial Ross App. No. 25CA24 2

responsibility law suspension in violation of R.C. 4510.16, and a display of license plate

violation under R.C. 4503.21. She initially pleaded not guilty and filed a motion to

suppress challenging the lawfulness of the traffic stop, and by extension, evidence

obtained because of the stop.

{¶3} At the suppression hearing, Trooper Dalton Chaffin of the Ohio State

Highway Patrol testified that on January 26, 2025, he was on routine patrol in a marked

cruisier when he observed Arnold’s vehicle as they both traveled northbound on U.S. 23.

Her vehicle had a tinted license plate cover. He testified that “you couldn’t - - you can’t

read what the license plate said on it. It was obstructing its view.” Trooper Chaffin

testified that the license plate had a “plastic dark-colored cover. It was transparent but

not transparent enough to where you could see it.” He testified, “So as window tint distorts

regular glass on your windows, it does the same thing for your license plate to where you

can’t see what’s beyond the window or the license plate cover.” When asked “from how

far away does one need to be to see the license plate,” he testified, “I believe it’s 50 feet.

I could be - - it is 50-to-100.” He testified approximately two car lengths is “40 to 50 feet

at least.” He was 50 feet away “at multiple points” and could not see the license plate

clearly. He also could not read the plate when he was 15 to 20 feet away “[d]ue to the

tint of the license plate, how dark it was.” On cross-examination, Trooper Chaffin

acknowledged the bottom half of the rear of the vehicle was in the shade.

{¶4} Trooper Chaffin conducted a traffic stop. He testified his usual procedure is

to initiate the stop “from my MCT” and “then call out the plate before I ever turn on my

lights.” In this instance, he could not follow his usual procedure because he was unable

to read the plate before he stopped the vehicle due to the license plate cover obstructing Ross App. No. 25CA24 3

it. When he exited his cruiser and walked up to Arnold’s vehicle, he was able to read the

plate within a few feet of the vehicle.

{¶5} The trial court orally overruled the motion to suppress. The court found that

“the defendant’s tag appears darker than other cars in the video, other licenses plates,

although it wasn’t possible to read any of the license plates from the camera footage.”

The court found that the “tag is readable, most of the letters and numbers on it, when the

camera is right up behind it once the vehicles are stopped.” The court noted that the

defendant’s vehicle “does sort of position the license plate a little lower on the back of the

car than most vehicles do.” And the court acknowledged Arnold asserted that “it was

because of that it was shaded and it was potentially the shading that obstructed any view

that might have been there.” The court stated, “I think if we were talking about a situation

where there wasn’t any material on the license plate, maybe that would be a good

argument,” but “it seemed clear to me that that plastic cover did obstruct the visibility of

the license plate.” The court stated, “we’re dealing with plain language, ‘obstructs the

visibility,’ so it has to block or hinder or impair the ability to see the license plate and I

think that’s exactly what happened. That’s what the officer testified to. There wasn’t any

real refutation of the fact that it was a tinted plastic cover.” The court noted two Second

District Court of Appeals cases relied on by the State “seem exactly on point to me,” and

the court found that “there was sufficient reasonable cause to stop.”

{¶6} Subsequently, Arnold pleaded no contest to OVI in violation of R.C.

4511.19(A)(1)(a), and the trial court accepted the no contest plea, found Arnold guilty,

and sentenced her. The remaining charges were dismissed. Ross App. No. 25CA24 4

II. ASSIGNMENT OF ERROR

{¶7} Arnold presents one assignment of error: “The trial court erred by denying

Ms. Arnold’s motion to suppress evidence that was discovered from an unlawful traffic

stop.”

III. LAW AND ANALYSIS

{¶8} In the sole assignment of error, Arnold contends the trial court erred by

denying her motion to suppress evidence that was discovered from an unlawful traffic

stop. Arnold maintains that the trial court erred when it rejected her argument about the

role the shade played in the trooper’s view of the license plate, despite competent,

credible evidence that it affected his view of the plate. She claims “the trooper’s assertion

and the trial court’s ultimate decision that the shade played no role in rendering the plate

indiscernible from a distance was not supported by competent, credible evidence, and

should not be accepted by this Court.” She asserts the trooper acknowledged that the

placement of the plate and direction of the sun put the plate in the shade and that the

dashcam video shows this. She claims “the shade did affect the readability of the plate,

and once the trooper was close enough to counteract that shade, he could fully read the

plate.” She maintains that the trial court erroneously blamed the trooper’s difficulty in

reading the plate “entirely on the plastic cover” and that we should not hold her

responsible for the effects of the shade in making the plate challenging to read from a

distance.

{¶9} Arnold also maintains that the trial court erred in denying her motion

because the tinted cover did not make the license plate unreadable. She claims the trial

court relied on Second District cases that impermissibly added a requirement to R.C. Ross App. No. 25CA24 5

4503.21 which the statute does not include—that a license plate be readable from a

specific distance—and essentially held that having a tinted cover was a per se violation

of Ohio law. Arnold claims the plain language of R.C. 4503.21 “makes clear that its

purpose is to ensure that license plates are ultimately readable - not that they are perfectly

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Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 998, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-arnold-ohioctapp-2026.