State v. Dehart

2024 Ohio 599
CourtOhio Court of Appeals
DecidedFebruary 16, 2024
Docket2023-CA-8
StatusPublished

This text of 2024 Ohio 599 (State v. Dehart) 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. Dehart, 2024 Ohio 599 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Dehart, 2024-Ohio-599.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT DARKE COUNTY

STATE OF OHIO : : Appellee : C.A. No. 2023-CA-8 : v. : Trial Court Case No. 22-CR-00285 : MICHAEL S. DEHART : (Criminal Appeal from Common Pleas : Court) Appellant : :

...........

OPINION

Rendered on February 16, 2024

LUCAS W. WILDER, Attorney for Appellant

R. KELLY ORMSBY, III, Attorney for Appellee

.............

WELBAUM, J.

{¶ 1} Michael S. Dehart appeals from his conviction on one count of aggravated

drug possession, a fifth-degree felony.

{¶ 2} In his sole assignment of error, Dehart challenges the trial court’s overruling

of his motion to suppress methamphetamine found in his car. He contends two sheriff’s

deputies lacked reasonable, articulable suspicion of criminal activity to detain him in his -2-

parked car and to inquire about his possession of contraband. He asserts that his consent

to search the car was involuntary, as it was given during an illegal detention, and that

methamphetamine found during the search should have been suppressed.

{¶ 3} We conclude that the deputies obtained permission to search the car during

a consensual encounter and that the trial court correctly overruled Dehart’s suppression

motion. Accordingly, the trial court’s judgment will be affirmed.

I. Facts and Course of Proceedings

{¶ 4} Following his indictment on one count of aggravated drug possession, Dehart

moved to suppress the evidence. The matter proceeded to a December 19, 2022

suppression hearing. Darke County Sheriff’s Deputy Steven Strunk was the only witness.

Strunk testified that he saw Dehart’s vehicle parked at a gas station in the early morning

hours of November 11, 2022. Strunk and another deputy, William Toomey, approached

the parked car to perform a welfare check on Dehart, who appeared to be asleep in the

driver’s seat. Strunk immediately recognized Dehart from prior interactions and knew that

he had a suspended driver’s license.

{¶ 5} Strunk knocked on the driver’s side window and awakened Dehart. Strunk

testified that Dehart responded by opening the car door. Strunk asked whether Dehart

was okay, and Dehart responded affirmatively. The deputy also asked whether Dehart

had been driving the car. Dehart stated that someone else had driven and had left him

there. Strunk then asked whether Dehart was in possession of any weapons or

contraband, and Dehart responded negatively. At that point, the deputy requested

consent to search the car. Dehart granted Strunk consent to search and stepped out of -3-

the car. Strunk found a baggie of methamphetamine in the center console. Upon finding

the drugs, Strunk arrested Dehart. In addition to Strunk’s testimony, the State admitted

into evidence cruiser-camera recordings from two police cruisers.

{¶ 6} Following the hearing, the trial court overruled Dehart’s suppression motion

in a written decision. The trial court first determined that the two police cruisers did not

block Dehart’s vehicle. In fact, the trial court noted that Dehart’s car was removed

following his arrest without the need to reposition either cruiser. Based on its review of

the cruiser-camera recordings, the trial court next found it “indeterminable” whether

Strunk or Dehart had opened Dehart’s car door. But even if Strunk opened the door, the

trial court found that the welfare check allowed him to do so. With regard to Dehart’s

argument that Strunk lacked reasonable, articulable suspicion of criminal activity after

confirming his welfare and his denial of driving, the trial court reasoned:

Defendant further argues that, after the welfare check was complete,

the deputies had no reasonable, articulable suspicion of criminal activity.

Again, the Court views the initial meeting of law enforcement and the

Defendant as a consensual encounter. In less than one minute, Deputy

Strunk introduced himself, inquired of the Defendant’s status, obtained

consent to search the vehicle, and was granted consent to search the

Defendant’s person. In fact, Defendant gave consent to search the vehicle

and even offered to voluntarily get out of the car. Deputy Strunk then asked

Defendant, “You ain’t got nothing on you, right?” Defendant replies, “No,”

and subsequently consented to the search of his person. Once the consent -4-

to search had been granted, Defendant’s arguments become moot. And the

Court does not find that law enforcement unreasonably detained Defendant

before requesting and obtaining consent.

January 11, 2023 Judgment Entry at 4-5.

{¶ 7} Dehart subsequently pled no-contest in exchange for the State’s agreement

to recommend community control at sentencing. The trial court accepted the plea, made

a finding of guilt, and sentenced Dehart to five years of community control.

II. Analysis

{¶ 8} In his sole assignment of error, Dehart challenges the trial court’s

suppression ruling. Dehart maintains that he was “seized” for Fourth Amendment

purposes when Strunk and Toomey positioned their cruisers in front of his car, leaving no

room for him to pull away, and Strunk knocked on his side window. Dehart contends this

seizure was unlawful as the deputies had no reason to believe he had committed or was

about to commit any crime. Dehart also reasons that Strunk’s questions about weapons

or contraband in the car and his request to search were investigatory insofar as they were

intended to confirm or dispel a mere “hunch” about illegal activity. Based on the premise

that he was detained illegally, Dehart asserts that his consent to search was invalid, as it

was tainted by and the product of illegal law-enforcement activity.

{¶ 9} When ruling on a motion to suppress, a trial court “assumes the role of the

trier of fact, and, as such, is in the best position to resolve questions of fact and evaluate

the credibility of the witnesses.” (Citation omitted.) State v. Retherford, 93 Ohio App.3d

586, 592, 639 N.E.2d 498 (2d Dist.1994). As a result, when we review suppression -5-

decisions, “we are bound to accept the trial court’s findings of fact if they are supported

by competent, credible evidence. Accepting those facts as true, we must independently

determine as a matter of law, without deference to the trial court’s conclusion, whether

they meet the applicable legal standard.” Id.

{¶ 10} The Fourth Amendment to the United States Constitution and Article I,

Section 14, of the Ohio Constitution protect persons from unreasonable searches and

seizures. State v. Leak, 145 Ohio St.3d 165, 2016-Ohio-154, 47 N.E.3d 821, ¶ 13.

Searches and seizures conducted without a warrant are per se unreasonable absent a

few, well recognized exceptions. Katz v. United States, 389 U.S. 347, 88 S.Ct. 507, 19

L.Ed.2d 576 (1967); State v. Adams, 144 Ohio St.3d 429, 2015-Ohio-3954, 45 N.E.3d

127, ¶ 181. One exception cited by the trial court in Dehart’s case “is the community

caretaking/emergency-aid exception, which is grounded in interests of public safety.”

State v. Glowney, 2d Dist. Montgomery Nos. 27896 and 27897, 2019-Ohio-3390, ¶ 34. A

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Related

Katz v. United States
389 U.S. 347 (Supreme Court, 1967)
United States v. Mendenhall
446 U.S. 544 (Supreme Court, 1980)
State v. Adams (Slip Opinion)
2015 Ohio 3954 (Ohio Supreme Court, 2015)
State v. Leak (Slip Opinion)
2016 Ohio 154 (Ohio Supreme Court, 2016)
State v. Retherford
639 N.E.2d 498 (Ohio Court of Appeals, 1994)
State v. Lewis, 22726 (1-16-2009)
2009 Ohio 158 (Ohio Court of Appeals, 2009)
State v. Windle
2017 Ohio 7813 (Ohio Court of Appeals, 2017)
State v. Glowney & Glowney
2019 Ohio 3390 (Ohio Court of Appeals, 2019)
State v. McCarthy
2022 Ohio 4738 (Ohio Court of Appeals, 2022)

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Bluebook (online)
2024 Ohio 599, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-dehart-ohioctapp-2024.