State v. Gipp

2024 Ohio 1076
CourtOhio Court of Appeals
DecidedMarch 22, 2024
Docket29983
StatusPublished

This text of 2024 Ohio 1076 (State v. Gipp) 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. Gipp, 2024 Ohio 1076 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Gipp, 2024-Ohio-1076.]

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

STATE OF OHIO : : Appellant : C.A. No. 29983 : v. : Trial Court Case No. 23 CRB 2642 : STEVEN GIPP, JR. : (Criminal Appeal from Municipal Court) : Appellee : :

...........

OPINION

Rendered on March 22, 2024

MARC T. ROSS, Attorney for Appellant

KAILA L. MCCLELLAN, Attorney for Appellee

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

HUFFMAN, J.

{¶ 1} The State appeals from the trial court’s order granting Steven Gipp Jr.’s

motion to suppress evidence. Because we conclude that police officers had a

reasonable belief that Gipp had committed domestic violence when they arrested him,

the trial court’s judgment will be reversed, and the matter will be remanded for further -2-

proceedings.

FACTS AND PROCEDURAL HISTORY

{¶ 2} On July 17, 2023, Gipp was charged by complaint with obstructing official

business and resisting arrest. The events giving rise to Gipp’s arrest occurred earlier

that day when J.S., Gipp’s former girlfriend and the mother of his child, reported that Gipp

had committed domestic violence against her at his home on Hamilton Avenue. After

Officer Green met with J.S. at a different location, he instructed Officers Lyons and

Moreland, who were on patrol close to Gipp’s residence, to arrest Gipp for “domestic

violence/threats.” Gipp did not cooperate when the officers attempted to arrest him,

which led to the charges of obstructing official business and resisting arrest.

{¶ 3} The matter was scheduled for trial on September 11, 2023, and then reset

for September 18, 2023. On September 12, 2023, Gipp filed a motion to suppress the

evidence related to obstructing and resisting arrest on the basis that his arrest had been

“based on neither probable cause nor a duly executed arrest warrant.” A hearing on the

motion to suppress occurred on September 18, 2023; the three officers involved in Gipp’s

arrest testified. The court granted Gipp’s motion to suppress on November 22, 2023,

concluding that the officers had lacked probable cause to arrest him.

{¶ 4} The State appeals.

ASSIGNMENT OF ERROR AND ANALYSIS

{¶ 5} The State asserts the following assignment of error:

THE TRIAL COURT ERRED IN GRANTING APPELLEE’S MOTION

TO SUPPRESS EVIDENCE. -3-

{¶ 6} According to the State, the trial court failed to follow R.C. 2953.03(B) in

sustaining Gipp’s motion to suppress. The State asserts that the trial court’s findings of

fact were against the manifest weight of the evidence based upon improper inferences

and conclusions “beyond the actual evidence introduced” at the suppression hearing.

{¶ 7} Gipp responds that the trial court did not err in granting his motion to

suppress. He asserts that R.C. 2935.03, which allows a law enforcement officer to arrest

and detain a person found violating a law until a warrant can be obtained, does not lower

the constitutional standard of probable cause for arrest. He also asserts that the officers’

alleged good faith in this case should not lower the probable cause requirement. Gipp

argues that R.C. 2935.03 “does not nullify the Fourth Amendment” and that the General

Assembly does not have the authority to override constitutions protections.

{¶ 8} According to Gipp, J.S.’s version of events was difficult to follow and

unverified at the time of his arrest, and the Constitution requires more than “unreliable,

uncorroborated allegations” before a citizen can be deprived of his or her liberty. Gipp

emphasizes that an arrest without probable cause is per se unreasonable under the

Fourth Amendment. Gipp further asserts that the good faith exception only applies to an

officer’s reliance on a warrant issued by a judge or magistrate; “it does not apply to the

reliance of a statute [sic], and it does not apply to warrantless arrests.”

{¶ 9} In reply, the State asserts that the “reasonable ground” to arrest and detain

for an offense of violence referenced under R.C. 2935.03(B) must mean something

different than probable cause “or else the legislature simply would have used the words

‘probable cause.’ ” The State cites State v. O’Neill, 2015-Ohio-815, 29 N.E.3d 365 (3d -4-

Dist.), a domestic violence case, which held that the “reasonable grounds” enumerated

in R.C. 2935.03(B)(3)(a)(i) and (ii) expressly permit an officer to find probable cause in

circumstances where the officer may not have witnessed the suspect committing a

domestic violence offense. Regarding the good faith exception, the State argues that

courts have applied it to cases in which officers reasonably relied in good faith on statutes

to make arrests and such statutes were later found to be unconstitutional. According to

the State, the officers in this case “reasonably relied in good faith on R.C. 2935.03(B) and

department policy” in effectuating Gipp’s arrest, and “any evidence obtained in

effectuating that arrest, including testimony and evidence that [Gipp] resisted or

obstructed,” should not have been suppressed.

{¶ 10} At the hearing on the motion to suppress, the State initially argued that

Gipp’s motion to suppress was untimely and also that the basis for the motion, namely

that there had not been probable cause for his arrest, was an issue for trial. The State

further asserted that there was no evidence obtained as a result of the arrest that was

subject to suppression. Gipp’s attorney responded that if the arrest was “bad,” then any

evidence obtained as a result of it should be suppressed, including the testimony of the

officers who were involved and any evidence that Gipp had resisted arrest or obstructed

official business.

{¶ 11} The trial court concluded that, although the motion to suppress was

untimely filed less than seven days before trial, it would hear the motion “in the interest of

justice.”

{¶ 12} The evidence at the suppression hearing was as follows. -5-

{¶ 13} Dayton Police Officer William Green testified that on July 17, 2023, he was

dispatched on a domestic violence call involving Gipp. The complainant was Gipp’s

former girlfriend and the mother of his child, J.S., who was at an address on Valerie Arms

Drive, and Green met her there. J.S. reported to Green that Gipp had threatened to

harm her at his home on Hamilton Avenue, where he lived with his mother. J.S. advised

Green that Gipp told her, “Come on out here so I can hit you in your s***,” and that he

picked up a plastic child’s basketball hoop and made a motion like he was going to swing

it at her before his mother interrupted him.

{¶ 14} After speaking to J.S., Green contacted Officers Moreland and Lyons, who

were closer to the Hamilton Avenue address than Green was. Green informed the other

officers that he had “a domestic violence/threats charge” on Gipp. Green gave them the

Hamilton Avenue address and asked them to speak with Gipp, get his side of the story,

“and make an arrest” for “domestic violence/threats.” Green then completed the

domestic violence victim’s packet with J.S. per department policy. According to Green,

because J.S. and Gipp had a child in common, “it would count as a domestic violence

charge,” and Gipp had threatened to strike J.S., which she took “as a legitimate threat.”

Green testified that J.S. had believed Gipp was trying to hit her with the basketball hoop

and had been afraid he would do so.

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Bluebook (online)
2024 Ohio 1076, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-gipp-ohioctapp-2024.