OH4: State was sufficiently on notice from motion to suppress to know to call the dog handler at the hearing

Defendant’s motion to suppress was sufficiently detailed [not a lot but still enough] to put the state on notice what the issues were at the suppression hearing, and the state was not entitled to a continuance at the hearing to get the dog handler there to testify to finding the drugs. State v. Rife, 2012 Ohio 3264, 2012 Ohio App. LEXIS 2856 (4th Dist. July 10, 2012).

Walking through the parking lot of a closed business at 1:30 am to an illegally parked car is reasonable suspicion. State v. Pittman, 2012 Ohio 3297, Ohio App. LEXIS 2900 (6th Dist. July 20, 2012).*

When the officer stopped defendant for a headlight being out, she was asked “is there anything in the car I should be concerned about,” and she produced a pipe. That was enough to get her out of the car and extend the stop further. State v. McDaniel, 2012 Ohio 3286, 2012 Ohio App. LEXIS 2887 (2d Dist. July 20, 2012).*