OH5: Citizen’s suspicious person call alone doesn’t support a stop

Other than a citizen’s telephone call, the officer admitted there was nothing about defendant that made him look suspicious or that he was up to no good. The stop and frisk was suppressed. State v. Hall, 2017-Ohio-5805; 2017 Ohio App. LEXIS 2862 (5th Dist. July 11, 2017).

The stop for following too close was justified, and that led to a consensual encounter. United States v. Haulcy, 2017 U.S. Dist. LEXIS 104445 (D.N.M. July 6, 2017).*