State v. Beckett

2026 Ohio 697
Ohio Court of Appeals·Decided March 2, 2026·No. 25CA012219·Published

Opinion

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

STATE OF OHIO C.A. No. 25CA012219 Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE

ERNEST BECKETT COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO

Appellant CASE No. 22CR107559

DECISION AND JOURNAL ENTRY Dated: March 2, 2026

CARR, Presiding Judge.

{¶1} Appellant, Ernest Beckett, appeals the judgment of the Lorain County Court of Common Pleas. This Court affirms in part, reverses in part, and remands for further proceedings.

I.

{¶2} This matter arises out an incident that occurred on October 1, 2022, where Beckett fled from police during a traffic stop in Lorain. Police stopped Beckett’s vehicle soon thereafter and he was placed under arrest.

{¶3} The Lorain County Grand Jury indicted Beckett on one count of failure to comply with an order or signal of a police officer with an attendant firearm specification, one count of having weapons while under disability, one count of tampering with evidence with an attendant firearm specification, one count of receiving stolen property with an attendant firearm specification, one count of carrying a concealed weapon, and one count of improperly handling a firearm in a motor vehicle. Beckett pleaded not guilty to the charges at arraignment.

{¶4} Beckett filed a motion to suppress the evidence obtained by police during the incident. The trial court held a hearing and then subsequently issued a journal entry denying the motion to suppress. Thereafter, Beckett appeared for a change-of-plea hearing where he pleaded no contest to the charges in the indictment. The trial court found Beckett guilty. The trial court imposed an aggregate prison sentence of two and a half years.

{¶5} On appeal, Beckett raises two assignments of error.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT ERRED IN DENYING APPELLANT’S MOTION TO SUPPRESS.

{¶6} In his first assignment of error, Beckett argues that the trial court erred in denying his motion to suppress. This Court disagrees.

{¶7} This Court’s review of the trial court’s ruling on the motion to suppress presents a mixed question of law and fact. State v. Burnside, 2003-Ohio-5372, ¶ 8. The trial court acts as the trier of fact during a suppression hearing and is best equipped to evaluate the credibility of witnesses and resolve questions of fact. Id.; State v. Hopfer, 112 Ohio App.3d 521, 548 (2d Dist. 1996), quoting State v. Venham, 96 Ohio App.3d 649, 653 (4th Dist. 1994). Consequently, this Court accepts a trial court’s findings of fact if supported by competent, credible evidence. Burnside at ¶ 8. Once this Court has determined that the trial court’s factual findings are supported by the evidence, we consider the trial court’s legal conclusions de novo. See id. In other words, this Court then accepts the trial court’s findings of fact as true and “must then independently determine, without deference to the conclusion of the trial court, whether the facts satisfy the applicable legal standard.” Id., citing State v. McNamara, 124 Ohio App.3d 706, 710 (4th Dist. 1997).

Background

{¶8} In support of his motion to suppress, Beckett sought to suppress all of the evidence obtained by police on October 1, 2022, on the basis that police did not have a lawful basis to stop his vehicle or place him under arrest.

{¶9} Officer Daniel Cole of the Lorain Police Department was the only witness to testify on behalf of the State at the suppression hearing. Beckett’s father and the mother of his children testified on behalf of the defense.

{¶10} Based on the evidence presented at the suppression hearing, the trial court made the following factual findings in its journal entry denying the motion to suppress:

On October 1, 2022, Officer Cole Daniel was on-duty as a city of Lorain police officer assigned to the Patrol Impact [Unit], tasked with enforcing laws against violent crimes, gun violence and illegal narcotics. On this evening, Officer Daniel testified that he stopped [Beckett] as his license plate was not readable from fifty feet at night in violation of Lorain Ordinance 337.04. After being asked for his identification and not being able to find it, [Beckett] put the vehicle back into drive and pulled away. A pursuit ensued during which [O]fficer Daniel lost visual contact of [Beckett]. Once he came around a curve, he observed [Beckett] stopped and took him into custody. Another officer discovered a firearm in a yard located in a place where [O]fficer Daniel did not have sight of [Beckett] during the pursuit.

The located firearm was determined to be stolen.

{¶11} Based on the foregoing findings, the trial court determined that Officer Daniel had a lawful basis to initiate the traffic stop of Beckett’s vehicle based on his observations that Beckett’s vehicle did not have sufficient rear license plate lighting in violation of Lorain Cod. Ord. 337.04. The trial court further determined that police had probable cause to place Beckett under arrest after Beckett fled during the traffic stop and failed to comply with the order of the police. To the extent that Beckett argued that the initial traffic stop violated R.C. 4549.13, which requires markings on police vehicles being used for the primary purpose of enforcing traffic laws, the trial court concluded that the vehicle requirements were not applicable in this case because

Officer Daniel’s primary assignment on the night of the incident was enforcing laws against violent crimes and illegal narcotics, not enforcing traffic laws.

Discussion

{¶12} In support of his first assignment of error, Beckett argues that the trial court’s finding that Officer Daniel observed a traffic violation was not supported by competent, credible evidence. Beckett contends that Officer Daniels’ testimony “was inconsistent, to say the least” with respect to whether a license plate light issue existed that amounted to a breach of Lorain Cod. Ord. 337.04(b). Beckett further notes that the defense presented two witnesses who indicated that Beckett’s plate light was in order.

{¶13} As noted above, Officer Daniel was the only witness to testify on behalf of the State at the suppression hearing. Officer Daniel testified that, in his capacity as a Lorain police officer, he serves on the Patrol Impact Unit, which is tasked with enforcing laws against violent crimes, gun violence, and illegal narcotics. While Officer Daniel sometimes enforces traffic laws, that is not the main purpose of his unit. Officer Daniel explained that he often initiates traffic stops that are connected to a criminal investigation and unrelated to traffic offenses. On the evening of October 1, 2022, Officer Daniel was assigned to the Patrol Impact Unit. After hearing the aforementioned testimony, the trial court took a brief recess. The trial court then made a ruling that a violation of R.C. 4549.13 had not occurred because Officer Daniel’s primary purpose on the night of the incident was not enforcing traffic laws.

{¶14} Thereafter, Officer Daniel testified that he was positioned in the Tower Boulevard area of Lorain on the night in question. The Patrol Impact Unit was conducting surveillance on Rag’s Liquor Store. While positioned at that location, Officer Daniel observed a pickup truck

being driven by Beckett, and noticed that the license plate was not readable from 50-feet away in violation of Lorain Cod. Ord. 337.04.

{¶15} Lorain Cod. Ord. 337.04, which pertains to taillights and the illumination of rear license plates, states as follows

(a) Every motor vehicle, trailer, semitrailer, pole trailer or vehicle which is being drawn at the end of a train of vehicles shall be equipped with at least one tail light mounted on the rear which, when lighted, shall emit a red light visible from a distance of 500 feet to the rear, provided that in the case of a train of vehicles only the tail light on the rear-most vehicle need be visible from the distance specified.

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State v. Beckett, 2026 Ohio 697 (Ohio Ct. App. 2026).

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