State v. Caughenbaugh

CourtOhio Court of Appeals
DecidedMarch 30, 2026
Docket2025-CA-00073
StatusPublished

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

Opinion

[Cite as State v. Caughenbaugh, 2026-Ohio-1153.]

COURT OF APPEALS LICKING COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO Case No. 2025-CA-00073

Plaintiff - Appellant Opinion And Judgment Entry

-vs- Appeal from the Municipal Court, Case No. 24- TRC-09733 KORI R. CAUGHENBAUGH Judgment: Reversed and Remanded Defendant - Appellee Date of Judgment Entry: March 30, 2026

BEFORE: Andrew J. King; William B. Hoffman; Craig R. Baldwin, Judges

APPEARANCES: J. MICHAEL KING, for Plaintiff-Appellant; ROBERT E. CALESARIC, for Defendant-Appellee

King, P.J.

{¶ 1} Plaintiff-Appellant, State of Ohio, appeals the October 14, 2025 judgment

entry of the Licking County Municipal Court granting the motion to suppress filed by

Defendant-Appellee, Kori R. Caughenbaugh. We reverse the trial court.

FACTS AND PROCEDURAL HISTORY

{¶ 2} On November 15, 2024, Ohio State Highway Patrol Sergeant Joshua Carte

stopped Caughenbaugh after observing her driving and crossing the double yellow center

line of the road. Caughenbaugh was subsequently charged with driving while impaired in

violation of R.C. 4511.19(A)(1)(a) and (d) and left of center in violation of R.C. 4511.25.

{¶ 3} On January 2, 2025, with leave of court, Caughenbaugh filed a motion to

suppress, arguing in part that Sergeant Carte lacked reasonable suspicion to pull her over.

A hearing was held on February 11, 2025; the trial court heard Sergeant Carte's testimony and watched dashcam footage of the claimed violation. Because Caughenbaugh's vehicle

was some distance from Sergeant Carte's cruiser and because of darkness and poor

weather conditions, the dashcam video does not visibly show Caughenbaugh's vehicle

crossing the center line of the road. By judgment entry filed March 7, 2025, the trial court

granted Caughenbaugh's motion, finding Sergeant Carte lacked probable cause to effect

the stop: "when there is a video recording of a defendant's allegedly unlawful operation of

a vehicle and it is not discernibly corroborative of the testimony, the Court finds that the

evidence is insufficient to establish that a violation was committed."

{¶ 4} The State appealed. This court reversed the trial court's decision, finding:

"Because the trial judge appears to have relied solely on the dashcam video footage in

ruling on the suppression motion without giving any weight to the trooper's testimony,

the trial court's judgment is reversed and the case is remanded for further trial-court

proceedings." State v. Caughenbaugh, 2025-Ohio-3064, ¶ 9 (5th Dist.).

{¶ 5} On remand, the trial court once again granted the motion to suppress,

finding: "there is insufficient credible testimonial evidence that the defendant committed

a traffic infraction. Given that finding of fact, it is the Court's conclusion of law that the

initial stop was unlawful and constituted a violation of the defendant's Fourth

Amendment right to be free from unreasonable search and seizure."

{¶ 6} The State filed an appeal with the following assignment of error:

I

{¶ 7} "THE TRIAL COURT ERRED WHEN IT GRANTED THE APPELLEE'S

MOTION TO SUPPRESS." I

{¶ 8} In its sole assignment of error, the State claims the trial court erred in

granting Caughenbaugh's motion to suppress. We agree.

{¶ 9} As stated by the Supreme Court of Ohio in State v. Leak, 2016-Ohio-154, ¶

12:

"Appellate review of a motion to suppress presents a mixed question

of law and fact." State v. Burnside, 100 Ohio St.3d 152, 2003-Ohio-5372,

797 N.E.2d 71, ¶ 8. In ruling on a motion to suppress, "the trial court

assumes the role of trier of fact and is therefore in the best position to

resolve factual questions and evaluate the credibility of witnesses." Id.,

citing State v. Mills, 62 Ohio St.3d 357, 366, 582 N.E.2d 972 (1992). On

appeal, we "must accept the trial court's findings of fact if they are supported

by competent, credible evidence." Id., citing State v. Fanning, 1 Ohio St.3d

19, 20, 437 N.E.2d 583 (1982). Accepting those facts as true, we must then

"independently determine as a matter of law, without deference to the

conclusion of the trial court, whether the facts satisfy the applicable legal

standard." Id.

{¶ 10} We therefore hold that as a general matter determinations of reasonable

suspicion and probable cause should be reviewed de novo on appeal.

{¶ 11} The Fourth Amendment to the United States Constitution and Section 14,

Article I of the Ohio Constitution guarantee the right to be free from unreasonable

searches and seizures. State v. Mays, 2008-Ohio-4539, citing State v. Orr, 2001 Ohio 50. A traffic stop is constitutionally valid if an officer personally observes a traffic

violation or has a reasonable and articulable suspicion that a motorist has committed, is

committing, or is about to commit a crime. Dayton v. Erickson, 76 Ohio St.3d 3 (1996);

Delaware v. Prouse, 440 U.S. 648 (1979). Further, "[t]he propriety of an investigative

stop by a police officer must be viewed in light of the totality of the surrounding

circumstances." State v. Freeman, 64 Ohio St. 2d 291 (1980), paragraph one of the

syllabus. "Therefore, if an officer's decision to stop a motorist for a criminal violation,

including a traffic violation, is prompted by a reasonable and articulable suspicion

considering all the circumstances, then the stop is constitutionally valid." Mays at ¶ 8.

{¶ 12} In granting the motion to suppress, the trial court found the following in its

entirety:

This matter comes on to be heard upon the remand of the Fifth

District Court of Appeals after that honorable Court reversed this Court's

decision on the defendant's motion to suppress. In conformity with that

instruction, the Court finds, specific to this case only, that there is

insufficient credible testimonial evidence that the defendant committed a

traffic infraction. Given that finding of fact, it is the Court's conclusion of

law that the initial stop was unlawful and constituted a violation of the

defendant's Fourth Amendment right to be free from unreasonable search

and seizure.

Accordingly, the defendant's motion to suppress is GRANTED.

It is so ordered. {¶ 13} The State argues the trial court failed to explain why Sergeant Carte's

testimony was not credible and it applied the wrong standard in reviewing the

constitutionality of the traffic stop in question i.e., making a probable cause finding

instead of a reasonable and articulable suspicion finding. Appellant's Brief at 4-5. The

State argues under the totality of the circumstances, Sgt. Carte's unrefuted testimony as

to why he stopped Caughenbaugh's vehicle provided the basis to effectuate the traffic stop

for further investigation. Id. at 5.

{¶ 14} During the suppression hearing, Sergeant Carte testified to driving behind

Caughenbaugh and observing her go left of the double yellow center line. T. at 7, 10. He

observed "both the driver and the front driver's side left side and the rear left side

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Related

Delaware v. Prouse
440 U.S. 648 (Supreme Court, 1979)
State v. Leak (Slip Opinion)
2016 Ohio 154 (Ohio Supreme Court, 2016)
Ohio v. Freeman
414 N.E.2d 1044 (Ohio Supreme Court, 1980)
State v. Fanning
437 N.E.2d 583 (Ohio Supreme Court, 1982)
State v. Mills
582 N.E.2d 972 (Ohio Supreme Court, 1992)
State v. Burnside
797 N.E.2d 71 (Ohio Supreme Court, 2003)
State v. Caughenbaugh
2025 Ohio 3064 (Ohio Court of Appeals, 2025)
State v. Orr
2001 Ohio 50 (Ohio Supreme Court, 2001)
Dayton v. Erickson
1996 Ohio 431 (Ohio Supreme Court, 1996)

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Bluebook (online)
State v. Caughenbaugh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-caughenbaugh-ohioctapp-2026.