OH2: Break-ins in area in past no justification for this stop without RS

The justification for defendant’s stop was break-ins in the area, but there was no call of a break-in that day, no description of a suspect or a vehicle involved. The stop was without reasonable suspicion. State v. Lindsey, 2012 Ohio 3105, 2012 Ohio App. LEXIS 2731 (2d Dist. July 6, 2012).*

Defendant’s stop was justified by excessive noise from revving his engine in a parking lot. He was found under the influence, and the stop was valid. His complaint of a frisk is moot because nothing was found to be suppressed. State v. Brown, 2012 Ohio 3099, 2012 Ohio App. LEXIS 2726 (2d Dist. July 6, 2012).*

Heck didn’t bar a § 1983 action where the criminal defendant was fined and had no habeas review. Embassy Realty Invs. v. City of Cleveland, 2012 U.S. Dist. LEXIS 93053 (N.D. Ohio July 5, 2012).*