Background
Ohio State Highway Patrol Sergeant Joshua Carte stopped Kori Caughenbaugh after claiming that he saw the left-side tires of her vehicle cross a double-yellow center line. Caughenbaugh was charged with operating a vehicle while under the influence of alcohol and moved to suppress the evidence, arguing that Carte lacked lawful grounds for the stop. At the suppression hearing, Carte testified that he clearly observed the violation, but the dashcam recording—made under dark, drizzly conditions—did not clearly show the vehicle crossing the center line.
The municipal court granted suppression three times. After two earlier appellate reversals and remands, the trial court expressly found Carte’s testimony not credible, explaining that it credited what the video did or did not show over the trooper’s account. The court concluded that the State had established neither probable cause nor reasonable, articulable suspicion for the stop. The State appealed for a third time.
The Court’s Holding
The Fifth District affirmed the suppression order. It explained that a traffic stop based on an officer’s observation of a traffic violation is constitutionally permissible when supported by probable cause, and that even a minor violation can justify a stop. But the trial court, acting as the factfinder at the suppression hearing, was entitled to evaluate the trooper’s credibility.
Because the trial court expressly disbelieved Carte’s testimony that he witnessed a center-line violation, and because neither the dashcam footage nor the admitted still photographs demonstrated such a violation, nothing remained to support the stop. Deferring to the trial court’s credibility determination under the applicable standard of review, the appellate court held that suppression was proper on the specific facts presented.
Key Takeaways
- An officer’s observation of a traffic violation ordinarily supplies probable cause for a non-investigatory traffic stop, even when the violation is minor.
- At a suppression hearing, the trial court is the factfinder and is generally best positioned to assess witness credibility.
- Once the trial court rejected the trooper’s testimony, the inconclusive video and still images provided no factual basis for the stop.
Why It Matters
The decision underscores that an officer’s uncorroborated account does not automatically establish lawful grounds for a traffic stop when the trial court expressly finds that account not credible. Appellate courts remain bound by trial-level factual and credibility findings when those findings are supported by competent, credible evidence.
The ruling is fact-specific: it does not require video proof of every traffic violation or hold that inconclusive dashcam footage necessarily defeats an officer’s testimony. Rather, suppression followed because the trial court rejected the testimony and no other evidence supported the asserted violation.