State v. Franks

2026 Ohio 1594
Ohio Court of Appeals·Decided May 1, 2026·No. WD-25-015·Published

Opinion

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT

WOOD COUNTY

State of Ohio Court of Appeals No.WD-25-015

Appellee Trial Court No. 2024CR0181 v.

Elizabeth Franks DECISION AND JUDGMENT Appellant Decided: May 1, 2026

*****

Paul A. Dobson, Wood County Prosecutor and Kristofer Kristofferson, Assistant Prosecutor, for appellee.

David Klucas, for appellant.

*****

DUHART, J.

{¶ 1} Appellant, Elizabeth Franks, appeals from a judgment entered by the Wood County Court of Common Pleas convicting her, following a jury trial, of operating a vehicle while under the influence of alcohol. For the reasons that follow, the trial court’s judgment is affirmed in part, and reversed in part.

Statement of the Case

{¶ 2} On May 2, 2024, the Wood County grand jury returned a two-count indictment charging Franks with offenses related to a traffic accident that occurred on

December 12, 2023. Count 1 charged her with operating a vehicle under the influence of alcohol, a drug of abuse, or a combination of them (“OVI”) under R.C. 4511.19(A)(1)(a) and R.C. 4511.19(G)(1)(d), as Franks had five prior convictions for OVI. Count 2 was also for OVI, but under R.C. 4511.19(A)(2)(a), R.C. 4511.19(A)(2)(b), and R.C. 4511.19(G)(1)(d), for her refusal to submit to chemical tests and for her prior OVI convictions. Both counts were felonies of the fourth degree, and both counts carried a repeat OVI offender specification under R.C. 2941.1413(A).

{¶ 3} Franks filed a motion to suppress wherein she alleged that: 1) the police lacked reasonable suspicion to request that Franks complete field sobriety tests; 2) the police lacked probable cause to arrest her for OVI; and 3) the police failed to substantially comply with the NHTSA manual when administering field sobriety tests. Regarding photographs of the scene that were initially thought by the parties to have been destroyed, she asserted that the State was obligated to show either that the photographs were destroyed prior to Franks’s request or that the photographs were not materially exculpatory.

{¶ 4} An initial hearing on the motion to suppress was held on August 26, 2024.

Following the hearing, the trial court took the matter under advisement. While the matter was still pending, the trial court indicated to counsel that it intended to deny the motion to suppress and issue an order to that effect. After that, but before the trial court’s issuance of an order, the State digitally recovered the pictures that were previously thought to have been destroyed. The defense objected to any use of the pictures, while the State sought to supplement the evidence with them in connection with the motion to suppress.

{¶ 5} On October 31, 2024, the trial court held a supplemental hearing to determine whether the photographs should be considered for purposes of the motion to suppress and, if so, to take testimony related to the pictures. Most of the photos depicted wreckage from the accident. Other photos depicted what appeared to be a water bottle, an unidentified can, an unopened Budweiser bottle, and a Bud Light can that may or may not have been opened. The State argued that the photos could be relevant to the question of whether the arresting officer had probable cause to conduct further investigation and probable cause to effect an OVI arrest. The defense argued that because the trial court had previously indicated its intention to deny the motion to suppress, Franks would suffer prejudice if the State were allowed to “retroactively bolster the evidence concerning probable cause.”

{¶ 6} The trial court indicated that the pictures “give context to the accident and what was in the car” and that defense counsel would have the ability to cross-examine the arresting officer about whether he remembered the cans being at the scene and how the cans had weighed into the officer’s considerations. The trial court, emphasizing that this was “a good faith situation,” overruled the defense’s objection.

{¶ 7} Thereafter, the trial court heard testimony from the arresting officer, who testified that the pictures were taken on the night of the crash and, further, were fair and accurate depictions of the scene. A second officer testified that the photos had been mistakenly believed to be lost because they were never transferred into the police department’s new crash report system. He stated that they were ultimately retrieved after he found them in the department’s old crash report system. Following this testimony, the trial court confirmed that the photos would be admitted for purposes of deciding the motion to suppress, “because the Court has to guarantee due process” and because the defense had demonstrated no apparent harm.

{¶ 8} On January 30, 2025, the trial court decided the motion to suppress, granting suppression of evidence of the administration and results of the horizontal gaze nystagmus test (because the test was not administered according to NHTSA standardized field sobriety testing manual requirements), but denying the rest of Franks’s claims.

{¶ 9} The case proceeded to a two-day jury trial beginning on February 5, 2025, and ending on February 6, 2025. Franks was found guilty on both counts and specifications.

{¶ 10} The trial court merged the two counts for purposes of sentencing, and the State elected to proceed on Count 2 and its corresponding specification. Franks was sentenced to serve two years in prison on the specification and to five years of community control on the underlying OVI offense, to begin upon Franks’s release from prison. As part of her community control, Franks was ordered to complete “any and all” requirements of the Intensive Supervision Program at SEARCH, a community-based correctional facility in Wood County. Franks’s counsel objected to the SEARCH term, arguing that if a prison term is imposed on the OVI, there should be no local term of incarceration.

Appellant timely filed an appeal.

Statement of the Facts

Motion to Suppress – August 26, 2024 Hearing

{¶ 11} Officer Tyler Dewitt of the Lake Township Police Department testified at the August 26, 2024 suppression hearing that he had specialized training in the detection of alcohol impairment, and that part of that training involved learning how to provide standardized field sobriety tests (“SFSTs”) in compliance with the NHTSA safety manual. He testified that prior to December 12, 2023, he had performed standardized field sobriety testing around 20 to 25 times and that he had charged people with OVI a total of 13 times. He also mentioned that the Lake Township Police department did not utilize dash or body cameras, and so his interaction with Franks would not have been recorded on the night in question.

{¶ 12} Regarding the night in question, Dewitt testified that on December 12, 2023, at around 1:30 a.m., he was on patrol on I-280 northbound, near the section of the roadway where I-280 southbound becomes State Route 420. He was stationed on the shoulder, watching oncoming traffic coming from I-90, i.e., the turnpike, when he heard a loud crashing sound. He turned and saw that a silver Dodge SUV had crossed several lanes of travel and struck a nearby guardrail. Dewitt then watched the silver SUV as it first moved into reverse and then began traveling southbound on State Route 420. Dewitt stated that he soon located the silver SUV, disabled and smoking, on the shoulder of the road. He noted that the car had heavy front-end damage, a back passenger tire that was completely flat, and a rear window that was “busted out.”

{¶ 13} Dewitt testified that due to the smoke coming from the vehicle, his immediate priority and concern was to get the occupant out for safety reasons. He testified that a can fell out of the car as Franks exited the vehicle, and that she stumbled and almost fell “face first” on the roadside as she attempted to retrieve it. Dewitt described that Franks was “unsteady on her feet” and “stumbling,” and that she started to wander in the wrong direction as they were going back to his car.

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State v. Franks, 2026 Ohio 1594 (Ohio Ct. App. 2026).

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