State v. Dowdell

2025 Ohio 5474
CourtOhio Court of Appeals
DecidedDecember 8, 2025
Docket2025-L-062
StatusPublished

This text of 2025 Ohio 5474 (State v. Dowdell) 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. Dowdell, 2025 Ohio 5474 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Dowdell, 2025-Ohio-5474.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT LAKE COUNTY

STATE OF OHIO, CASE NO. 2025-L-062

Plaintiff-Appellee, Criminal Appeal from the - vs - Court of Common Pleas

BENJAMIN DOWDELL, JR., Trial Court No. 2024 CR 001252 Defendant-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: December 8, 2025 Judgment: Affirmed

Charles E. Coulson, Lake County Prosecutor, and Jennifer A. McGee, Assistant Prosecutor, Lake County Administration Building, 105 Main Street, P.O. Box 490, Painesville, OH 44077 (For Plaintiff-Appellee).

Vanessa R. Clapp, Lake County Public Defender, and Paul J. Lubonovic, Assistant Public Defender, 100 West Erie Street, Painesville, OH 44077 (For Defendant- Appellant).

SCOTT LYNCH, J.

{¶1} Defendant-appellant, Benjamin Dowdell, Jr., appeals the denial of his

Motion to Suppress in the Lake County Court of Common Pleas. For the following

reasons, we affirm the decision of the court below.

Procedural History

{¶2} On December 20, 2024, Dowdell was charged with one count of Aggravated

Possession of Drugs and two counts of Possession of Cocaine.

{¶3} Dowdell filed a Motion to Suppress which was denied on March 4, 2025. {¶4} Dowdell subsequently pled “no contest” to Aggravated Possession of Drugs

and one count of Possession of Cocaine.

{¶5} On May 1, 2025, the trial court sentenced Dowdell to concurrent prison

terms of six months for each count, stayed pending appeal.

Assignment of Error

{¶6} On appeal, Dowdell raises the following assignment of error: “The trial court

erred when it denied defendant-appellant’s Motion to Suppress.”

Standard of Review

{¶7} “Appellate review of a motion to suppress presents a mixed question of law

and fact.” State v. Burnside, 2003-Ohio-5372, ¶ 8. “When considering 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. “[A]n

appellate court must accept the trial court’s findings of fact if they are supported by

competent, credible evidence.” Id. “Accepting these facts as true, the appellate court

must then independently [i.e., de novo] determine, without deference to the conclusion of

the trial court, whether the facts satisfy the applicable legal standard.” Id.

Findings of Fact

{¶8} In denying Dowdell’s Motion to Suppress, the trial court made the following

factual findings:

On October 15, 2024, Patrolman Dallas McCloud (an acting sergeant at the time) was on patrol in the City of Painesville. At approximately 12:56 a.m., he encountered a vehicle being driven without a visible rear license plate. Patrolman McCloud followed the vehicle for approximately 200 yards before conducting a traffic stop for the lack of a rear license plate. When Patrolman McCloud stopped the vehicle, he was one to one-half car lengths behind the vehicle. It was only when Patrolman McCloud shined his vehicle spotlight on

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Case No. 2025-L-062 the vehicle that he observed the outline of what appeared to be a temporary placard in the top left corner of the rear windshield. He was still unable to read the characters on the placard.

Patrolman McCloud could only read the characters when he was approximately two feet from the placard and standing near the rear tire. He had to look straight down into the windshield to read the placard. Patrolman McCloud admitted that the placard was flush with the windshield, was securely taped to the windshield, and had no physical obstructions.

Patrolman McCloud approached the driver and observed four additional occupants. He recognized a female and Defendant, who was seated in the rear middle seat. Knowing that the female and Defendant were drug users, Patrolman McCloud requested a drug canine to conduct a search of the vehicle. Officers discovered narcotics on Defendant’s person, resulting in his arrest. He was indicted on three counts of Possession of Drugs, all felonies of the fifth degree. The driver was issued a citation for Display of License Plates under Painesville Ordinance 336.09.

Patrolman McCloud had Probable Cause to Issue a Citation to the Driver of the Vehicle in which Dowdell was a Passenger for Violating Painesville Cod.Ord. 336.09(a)(3)

{¶9} Patrolman McCloud initiated the traffic stop based on a violation of

Painesville Cod.Ord. 336.09(a)(3) – substantially identical to R.C. 4503.21(A)(3) – which

provides: “No person to whom a temporary motor vehicle license registration has been

issued for the use of a motor vehicle under R.C. § 4503.182, and no operator of that motor

vehicle, shall fail to display the temporary motor vehicle license registration in plain view

from the rear of the vehicle either in the rear window or on an external rear surface of the

motor vehicle.” The trial court interpreted the words “plain view” to mean “‘actually being

able to read the letters and numbers’ on the temporary license placard being displayed

from the rear of one’s vehicle.” (Citation omitted.) State v. Smith, 2022-Ohio-2383, ¶ 3

(12th Dist.). Dowdell maintains that neither the ordinance nor the statute requires that

the temporary registration be legible from any particular distance. Because “McCloud

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Case No. 2025-L-062 could in fact read the numbers and letters on the temporary registration, without

obstruction,” the fact “[t]hat he had to get out of his cruiser to do so is irrelevant to the

statutory requirement.” Brief of Defendant-Appellant at 12. “Therefore, as a matter of

law, there was no violation of the ordinance.” Id.

{¶10} Dowdell acknowledges that the initial stop was valid: “Because [Patrolman

McCloud] could not see a license plate and could not easily see the temporary registration

from his cruiser, he had an objectively reasonable basis to conclude that the [vehicle] did

not have a valid temporary tag” and “could initiate a stop.” Id. at 14. Further, “[h]e was

permitted [under State v. Dunlap, 2024-Ohio-4821] to approach the driver to ask for

identification and to explain the reason for the stop.” Id. However, Dowdell asserts, he

could do no more than that. “Once he determined that temporary registration was valid,

flush against the window, and unobstructed, … McCloud lacked the probable cause or

reasonable suspicion necessary to keep the [vehicle] detained while he wrote a ticket and

waited for the K9 to arrive.” Id.

{¶11} We disagree that Patrolman McCloud lacked probable cause to issue a

citation merely because the registration was visible at a distance of two feet and when he

was looking “straight down.” Dowdell’s interpretation of “plain view” is far from being the

settled law of this appellate district or of the state. In State v. Anderson, 2018-Ohio-2455

(11th Dist.), this court determined that the registration was not in plain view “[s]ince [the

officer] could only see the license plate number after he approached the vehicle on foot

following the stop.” Id. at ¶ 18. It could be argued that Anderson is distinguishable from

the present case because the plate in Anderson was not flush or securely fastened to the

rear window. Rather, it was “propped up in the front windshield, was ‘tilted back’ and

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Case No. 2025-L-062 ‘wasn’t straight up and down where it was visible.’” Id. at ¶ 17. Nevertheless, the fact

that the issue of whether the ordinance was violated is debatable validates the propriety

of issuing a citation.

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Related

United States v. Ruel Antonio Wallace
213 F.3d 1216 (Ninth Circuit, 2000)
State v. Colton, Unpublished Decision (8-19-2005)
2005 Ohio 4494 (Ohio Court of Appeals, 2005)
State v. Anderson
2018 Ohio 2455 (Ohio Court of Appeals, 2018)
State v. Ware
2019 Ohio 3885 (Ohio Court of Appeals, 2019)
State v. Smith
2022 Ohio 2383 (Ohio Court of Appeals, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 5474, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-dowdell-ohioctapp-2025.