State v. Wheeler

2025 Ohio 5165
CourtOhio Court of Appeals
DecidedNovember 14, 2025
Docket2025-CA-9
StatusPublished

This text of 2025 Ohio 5165 (State v. Wheeler) 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. Wheeler, 2025 Ohio 5165 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Wheeler, 2025-Ohio-5165.]

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

STATE OF OHIO : : C.A. No. 2025-CA-9 Appellee : : Trial Court Case No. 2024CR0248 v. : : (Criminal Appeal from Common Pleas ERIK MICHEAL WHEELER : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on November 14, 2025, the judgment

of the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

EPLEY, P.J., and HANSEMAN, J., concur. OPINION GREENE C.A. No. 2025-CA-9

KRISTIN L. ARNOLD, Attorney for Appellant MEGAN A. HAMMOND, Attorney for Appellee

TUCKER, J.

{¶ 1} Defendant-appellant Erik Michael Wheeler appeals from his conviction of

operating a vehicle under the influence. For the reasons outlined below, we affirm.

I. Factual and Procedural Background

{¶ 2} On October 1, 2023, Fairborn Police Department Officers were dispatched to

Mann Avenue upon a report that a red truck had struck and damaged a tree located on the

caller’s residential lot, after which it had immediately left the scene. Officers Caleb Weaver

and Codie Henning responded separately to the call. Weaver went the scene of the tree

strike where he noted damage to a tree and a trail of fluid on the roadway leading away from

the tree. Weaver followed the trail and ultimately located a red truck parked partially on the

roadway and partially in the grass. Upon reaching the truck, Weaver found that Henning had

already reached the vehicle. The officers observed damage to the side of the truck, including

wood chips apparently embedded in the damaged portion of the vehicle.

{¶ 3} The officers spoke with the driver of the truck, Wheeler, who claimed he was

parked partially in the grass because the truck’s steering column was damaged and he was

having difficulty steering the vehicle. Wheeler denied consuming any alcohol. Wheeler said

that he was on his way home from a 12-hour work shift and that he was tired because he

had slept only approximately 6 hours in the past 48 hours. The officers asked Wheeler

whether he had hit anything while driving. Wheeler stated that he had hit a curb and that he

hits curbs “all the time.” When the officers asked whether he had hit a tree, Wheeler

2 responded, “no comment.” The officers did not smell an odor of alcohol but did notice

Wheeler had bloodshot and watery eyes. They also noted that his speech and movements

were slow and that his clothing was in “disarray.” The officers decided to conduct field

sobriety tests. Upon concluding the tests, the officers arrested Wheeler.

{¶ 4} On April 19, 2024, Wheeler was indicted on one count of operating a vehicle

under the influence of alcohol or drugs (“OVI”) in violation of R.C. 4511.19(A)(1)(a). Because

Wheeler had three prior OVI convictions within ten years of his offense, it constituted a

fourth-degree felony.

{¶ 5} On August 12, 2024, Wheeler filed a motion to suppress. A hearing was

conducted on October 30, 2024. Both officers testified. According to the officers, Wheeler

was “unable to logically recount the route he took home from work.” Based on Wheeler’s

conduct and appearance, both officers suspected that he was under the influence of drugs,

so they decided to conduct field sobriety testing.

{¶ 6} Officer Henning administered the testing. He testified his training included the

National Highway Traffic Safety Administration (“NHTSA”) standards for field sobriety testing

and Advanced Roadside Impaired Driving Enforcement (“ARIDE”) training. According to

Henning, he administered a mix of NHTSA and ARIDE testing to Wheeler.

{¶ 7} Henning initially administered the horizontal gaze nystagmus (“HGN”) test but

observed no indications of intoxication with that test. Henning then administered an ARIDE

test known as the lack of convergency test. Like the HGN test, the lack of convergency test

requires the subject to follow an object with their eyes. Henning testified he observed indicia

of intoxication with this test. Next Henning instructed Wheeler on the walk-and-turn test.

After being instructed twice, Wheeler was unable to repeat the instructions, and during the

test itself, he committed two errors. Henning also gave the one-legged-stand test and

3 observed Wheeler swaying and using his arms to maintain his balance. Wheeler also

performed the modified Romberg test, which required him to stand with his feet together,

eyes closed, and tilt his head slightly back while estimating the lapse of 30 seconds. He

properly performed that test. Finally, Wheeler was instructed on the finger-to-nose test,

which required him to touch his pointer finger to his nose. When Wheeler used his right

hand, he delayed starting the test and then missed his nose. When using his left hand,

Wheeler missed his nose and touched his face under his eye.

{¶ 8} The trial court denied the motion to suppress. Wheeler subsequently entered a

no-contest plea to the offense. The trial court sentenced him to a prison term of 30 months.

Wheeler appeals.

II. Suppression

{¶ 9} Wheeler’s assignment of error states:

THE TRIAL COURT ERRED IN DENYING THE MOTION TO SUPPRESS

BECAUSE LAW ENFORCEMENT UNLAWFULLY PROLONGED THE

TRAFFIC STOP AND LACKED A REASONABLE SUSPICION AND

PROBABLE CAUSE TO CONTINUE DETAINING AND ARRESTING MR.

WHEELER.

{¶ 10} Wheeler contends the trial court should have sustained his motion to suppress

evidence.

{¶ 11} The Fourth Amendment to the United States Constitution prohibits

unreasonable searches and seizures. Terry v. Ohio, 392 U.S. 1, 8 (1968). Warrantless

searches and seizures violate this prohibition unless conducted pursuant to one of the “few

specifically established and well-delineated exceptions.” Katz v. United States, 389 U.S.

347, 357 (1967). One of these exceptions “is commonly known as an investigative or Terry

4 stop,” which includes the temporary detention of motorists for the enforcement of traffic laws.

State v. Dorsey, 2005-Ohio-2334, ¶ 17 (10th Dist.), citing Terry at 1. Probable cause is not

required for a Terry stop. Id.; State v. Allen, 2021-Ohio-3047, ¶ 32 (2d Dist.). Rather, a police

officer may briefly stop and temporarily detain a person to investigate possible criminal

activity if the officer has a reasonable, articulable suspicion that criminal activity may be

afoot. Terry, 392 U.S. 1; State v. Mays, 2008-Ohio-4539, ¶ 7-8.

{¶ 12} Wheeler does not contest the appropriateness of the initial encounter with the

officers. Instead, he asserts the officers improperly prolonged the encounter by conducting

field sobriety testing without probable cause to do so. He claims that “[o]nce officers

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Related

Katz v. United States
389 U.S. 347 (Supreme Court, 1967)
Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
State v. Wells, Unpublished Decision (9-23-2005)
2005 Ohio 5008 (Ohio Court of Appeals, 2005)
State v. Knox, Unpublished Decision (6-16-2006)
2006 Ohio 3039 (Ohio Court of Appeals, 2006)
State v. Dorsey, Unpublished Decision (5-12-2005)
2005 Ohio 2334 (Ohio Court of Appeals, 2005)
State v. Hairston (Slip Opinion)
2019 Ohio 1622 (Ohio Supreme Court, 2019)
State v. Allen
2021 Ohio 3047 (Ohio Court of Appeals, 2021)
State v. Timson
311 N.E.2d 16 (Ohio Supreme Court, 1974)
State v. Andrews
565 N.E.2d 1271 (Ohio Supreme Court, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 5165, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-wheeler-ohioctapp-2025.