OH2: Mistaken entry of LPN into computer that resulted in erroneous stop still made the stop reasonable

The Ohio officer entered in the license number of an Illinois vehicle but omitted a letter in smaller type on the side that made the number complete because he didn’t know it was required. The wrong LPN came back as suspended. The stop was still reasonable even though the officer was mistaken in entering the number. State v. Nevarez-Reyes, 2017-Ohio-2610, 2017 Ohio App. LEXIS 1623 (2d Dist. April 28, 2017).

Officers had a reasonable belief that the consenter had apparent authority to consent: “Detective Boutwell had had previous conversations with neighbors who observed Anders and Ms. Spitnale hurriedly moving their personal belongings out of the home and into a trailer. He also learned from Ms. Walters, the property owner and landlord of the premises, that an eviction notice had been posted on the door of the home a month earlier and that Ms. Spitnale had acknowledged receipt of the notice and was given a week by Ms. Walters to vacate the home.” State v. Anders, 2017-Ohio-2589, 2017 Ohio App. LEXIS 1603 (3d Dist. May 1, 2017).*

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