“Here, Officer Pratt had independent reasonable suspicion for prolonging the traffic stop. He noted that the fact that the car was registered to one person and insured to another, neither of whom were the defendant, was a prominent indicator of narcotics trafficking. … Further, the defendant did not know who owned the vehicle, which the officer found to be “very significant.” … Also significant to the officer was the fact that only a single key was in the ignition. … Officer Pratt testified that these observations, combined with his extensive training and experience in narcotics interdiction, led him to believe the defendant “may be transporting narcotics.” … Officer Pratt’s identification of these indicia of narcotics trafficking occurred “within 20, 30 seconds” of his initiating contact with the defendant, at which time the officer’s focus shifted to “a narcotics stop.” … After he removed the defendant Alvarez from the car and continued talking with him, defendant Alvarez stated that he also did not know who had brought the vehicle to him. … Though he advised Officer Pratt that the vehicle had been dropped off to him at his uncle’s request, defendant Alvarez was unsure of his uncle’s name. … These facts were sufficient to give rise to a reasonable suspicion of narcotics trafficking, which justified prolonging the stop for further investigation.” United States v. Alvarez, 2016 U.S. Dist. LEXIS 177755 (E.D.Cal. Dec. 22, 2016).

The video of defendant’s driving shows that he drove entirely into another lane and nearly had an accident with another vehicle. When stopped, he was cooperative, didn’t smell of alcohol, and denied drinking. He did, however, have “glassy, bloodshot eyes, which are often, but not always, an indication of impairment. See State v. Lucking, 12th Dist. Butler No. CA2002-12-303, 2004-Ohio-90, ¶ 11 (‘[W]e find that glassy, bloodshot eyes are generally accepted as classic indicia of intoxication.’). Thus, based on the totality of the circumstances, we conclude that Trooper Ross possessed reasonable suspicion to administer the field sobriety tests in this case.” State v. Hochstetler, 2016-Ohio-8389, 2016 Ohio App. LEXIS 5240 (9th Dist. Dec. 27, 2016).*

The trial court’s findings of justification for defendant’s stop and then his conviction for DWI was supported by competent evidence and is affirmed. State v. Curran, 2016-Ohio-8502, 2016 Ohio App. LEXIS 5330 (9th Dist. Dec. 30, 2016).*

Defendant’s stop was objectively justified for the paper tag in the back window that couldn’t be read. The fact the officer may have a subjective pretext doesn’t make the stop objectively unreasonable. Here, the pretext was that the car was possibly involved in a shooting two days earlier. As the officer approached the car, she was watching the two occupants. Viewing the tag would have shown that it was current, but the case law strongly suggests that the “mission” of the stop isn’t immediately complete, and the officer can talk to the occupants even if the license is current. United States v. McLemore, 2016 U.S. Dist. LEXIS 177419 (N.D.Iowa Dec. 21, 2016), rejected and motion to suppress granted, 2017 U.S. Dist. LEXIS 27489 (N.D. Iowa Feb. 28, 2017) (posted here).