OH9: Hearing shots fired and seeing only vehicle in vicinity justified stop

Officers on patrol and parked at 2:40 am heard shots fired, and they headed in that direction. In a block, they saw a Yukon heading toward them driving slowly. There were no other vehicles or pedestrians around. They turned around and followed. Then a radio report came in of other shots fired 10 blocks away. They pulled the vehicle over and asked about weapons. The defendants consented to a patdown and got out of the car, and a gun was seen in plain view. It was properly seized because there was reasonable suspicion from the first hearing of shots. State v. Clayton, 2015-Ohio-663, 2015 Ohio App. LEXIS 634 (9th Dist. February 25, 2015).*

There was probable cause for defendant’s arrest: He failed to stop at a stop sign and struck another vehicle, his wife was ejected from the vehicle as a result of the collision, defendant pushed his car back onto the road and fled the scene, and he exhibited four out of six clues on the HGN test and admitted he had been drinking. State v. Richards, 2015-Ohio-669, 2015 Ohio App. LEXIS 625 (4th Dist. February 18, 2015).*

Defendant’s crossing the fog line three times and hitting the rumble strip twice was particularized suspicion for a stop. State v. Duong, 2015 MT 70, 378 Mont. 345 (March 3, 2015).*

Defendant’s stop for suspected DWI driving a motor home through a small town was with reasonable suspicion that he was the one the CI was talking about when the motor home stopped was following the CI and there were no others around. State v. Rose, 2015 UT App 49, 2015 Utah App. LEXIS 44 (February 26, 2015).*