State v. Dunlap

2024 Ohio 4821, 178 Ohio St. 3d 114
CourtOhio Supreme Court
DecidedOctober 9, 2024
Docket2022-1227
StatusPublished
Cited by1 cases

This text of 2024 Ohio 4821 (State v. Dunlap) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Dunlap, 2024 Ohio 4821, 178 Ohio St. 3d 114 (Ohio 2024).

Opinion

[This opinion has been published in Ohio Official Reports at 178 Ohio St.3d 114.]

THE STATE OF OHIO, APPELLANT, v. DUNLAP, APPELLEE. THE STATE OF OHIO, APPELLANT, v. LEWIS, APPELLEE. [Cite as State v. Dunlap, 2024-Ohio-4821.] Criminal law—Fourth Amendment to United States Constitution—Whether officer violated Fourth Amendment by asking driver for license after realizing that driver was not car’s owner—Court of appeals’ judgments reversed and trial court’s judgments reinstated. (Nos. 2022-1227, 2022-1229, 2022-1237, and 2022-1238—Submitted October 25, 2023—Decided October 9, 2024.) APPEAL from and CERTIFIED by the Court of Appeals for Geauga County, Nos. 2021-G-0034 and 2021-G-0037, 2022-Ohio-3006 and 2022-Ohio-3007. __________________ DEWINE, J., announced the judgment of the court, with an opinion joined by FISCHER and DETERS, JJ. DONNELLY, J., concurred in judgment only, with an opinion. STEWART, J., concurred in judgment only, with an opinion. KENNEDY, C.J., dissented, with an opinion joined by BRUNNER, J.

DEWINE, J., announcing the judgment of the court. {¶ 1} A police officer pulled over a car because he had information that the car’s owner had a suspended driver’s license. But when he walked up to the car, the officer realized that the car was not being driven by its owner. The officer asked the driver for his license and discovered that he also did not have a valid driver’s license. Ultimately, an illegal firearm was found in the vehicle and the driver and a passenger were arrested. {¶ 2} No one disputes that the police officer had probable cause to initiate the stop. The question we confront in this case is whether the officer violated the SUPREME COURT OF OHIO

Fourth Amendment by asking the driver for his license after he realized that the driver was not the car’s owner. We conclude that he did not. Under controlling United States Supreme Court precedent, an officer who has properly executed a traffic stop may make ordinary inquiries necessary to complete the mission of the traffic stop—including confirming that the driver has a valid driver’s license. See Rodriguez v. United States, 575 U.S. 348, 355 (2015). {¶ 3} The Eleventh District Court of Appeals held in these consolidated cases that the trial court erred in not suppressing evidence that was found in the car. Because we disagree, we reverse the judgments of the court of appeals and reinstate the judgments of the trial court. I. Background A. An officer stops a suspected unlicensed driver {¶ 4} Officer Andrew Centrackio sat in a parking lot running registration checks on the license plates of passing vehicles using the Law Enforcement Automated Data System (more commonly known as “LEADS”). Among the cars he checked was a Kia Forte with a rear temporary tag. The inquiry revealed that the Kia’s owner, Jessica Dunlap, had a suspended driver’s license. LEADS also provided some of Dunlap’s identifying traits, including her gender, height, age, and weight. {¶ 5} Acting on the information from LEADS, Officer Centrackio pulled the Kia over based on his suspicion that a suspended driver was behind the wheel. It was not until he walked up to the driver-side window that he realized that the car was not being driven by its owner: Jessica Dunlap is a white female, but the driver, later identified as Je’Brel Lewis, was an African American male. Dunlap was a passenger in the vehicle. {¶ 6} Officer Centrackio informed Lewis that he had pulled the car over because the registered owner had a suspended license. Referencing Dunlap, Lewis

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responded that “she got court for that.” Officer Centrackio then asked Lewis if his license was valid. Lewis responded, “I believe I’m valid. If not, she’s valid.” {¶ 7} At that point, Officer Centrackio asked Lewis for his license. Lewis instead pulled out a state-issued identification card. While walking back to the patrol car, Officer Centrackio said, “If you’re valid, you guys are good to go.” After running the information in LEADS, Officer Centrackio learned that Lewis also had a suspended license. Because neither Lewis nor Dunlap had a valid driver’s license, he called for a tow truck and prepared to conduct an inventory search. {¶ 8} From LEADS, Officer Centrackio knew that Lewis had active arrest warrants and that his prior charges included improper handling of firearms in a motor vehicle. He asked Lewis whether there were any weapons in the vehicle. Lewis stated that there was an unloaded firearm located in the front passenger-side door and gave the officer permission to search the car. The search revealed the firearm in the front passenger-side door and a loaded magazine on the floor of the back seat. B. The court of appeals rules that the evidence found in the car should be suppressed {¶ 9} Dunlap and Lewis were each indicted on one count of improperly handling firearms in a motor vehicle. They both filed motions to suppress the evidence discovered in the car, arguing that the officer had unlawfully prolonged the stop after he realized that Dunlap was not driving. {¶ 10} At a consolidated hearing on the suppression motions, Officer Centrackio testified that he asked Lewis for his license to “determine if he was valid” and “legally able to drive the vehicle.” He also said that he asked for identification in order to document Lewis’s identity in an incident report that is generated each time he stops a vehicle. {¶ 11} The trial court denied the motions to suppress. Both defendants pled no contest and appealed to the Eleventh District. On appeal, they argued that

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although the initial stop was justified, the officer violated the Fourth Amendment by continuing the stop after he realized that Dunlap was not driving the car. {¶ 12} The Eleventh District reversed the trial court’s denial of the motion to suppress in both cases. State v. Dunlap, 2022-Ohio-3007 (11th Dist.); State v. Lewis, 2022-Ohio-3006 (11th Dist.). It held that once Officer Centrackio realized that Dunlap was not the driver, he no longer had reasonable suspicion for the stop. Dunlap at ¶ 19; Lewis at ¶ 19. Therefore, the court reasoned, it was impermissible for the officer to continue the stop to ask Lewis for identification. See Dunlap at ¶ 19; Lewis at ¶ 19. Because “the extension of the stop was improper once [Officer] Centrackio recognized Dunlap was not the driver,” the court of appeals held that the firearm that was discovered as a result of the continued detention must be suppressed. Lewis at ¶ 29; see also Dunlap at ¶ 29. {¶ 13} The Eleventh District acknowledged that its decisions were in conflict with the Ninth District’s decision in State v. Graves, 1993 WL 261562 (9th Dist. July 14, 1993), and certified the conflicts to this court. In Graves, an officer stopped a car because its owner had an outstanding warrant, but after executing the stop the officer realized the car’s owner was not the person driving the car. Nonetheless, the Ninth District found that it was permissible for the officer to ask the driver for identification, explaining that “once a motor vehicle is legitimately stopped, . . . the slight intrusion of asking the driver for identity is neither unwarranted, nor prohibited.” Id. at *2, citing Berkemer v. McCarty, 468 U.S. 420, 439 (1984). {¶ 14} This court accepted both appeals, determined that the conflicts did exist, and consolidated all four cases for review. 2022-Ohio-4670. II. We Reverse the Court of Appeals and Reinstate the Convictions {¶ 15} The Fourth Amendment to the United States Constitution protects the “right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.” The Ohio Constitution also prohibits

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State v. Dunlap
2024 Ohio 4821 (Ohio Supreme Court, 2024)

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Bluebook (online)
2024 Ohio 4821, 178 Ohio St. 3d 114, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-dunlap-ohio-2024.