OH12: Officer’s reasonable mistake on traffic violation didn’t void stop

Did defendant violate the turn signal ordinance by not signaling his turn until already stopped? It doesn’t matter. “Ultimately, though, we need not decide whether Bryant actually violated the turn-signal ordinance. Even if the answer is unclear, Officer Singleton’s stop was justified so long as he had reasonable suspicion that a violation had occurred. And he did. An officer need not be right about a traffic violation to conduct a lawful stop—he need only be reasonable. A reasonable mistake of law can still constitute reasonable, articulable suspicion to justify a traffic stop.” State v. Bryant, 2026-Ohio-389 (12th Dist. Feb. 9, 2026). Similar is United States v. Schoggins, 2026 U.S. Dist. LEXIS 26841 (E.D. Okla. Feb. 10, 2026).

The trial court granted a motion to suppress. It was pointless to have a Franks hearing after that, so that’s not an error for appeal. Weber v. State, 2026 Tex. App. LEXIS 1212 (Tex. App. – Dallas Feb. 9, 2026).*

The misstatements aren’t material to the probable cause finding. United States v. Fassero, 2026 U.S. Dist. LEXIS 26414 (C.D. Ill. Feb. 9, 2026).*

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