Medina County Appellate Decisions for February, 2014

The Court of Appeals for the Ninth Appellate District released three decisions in February for appeals out of Medina County. All three of them were criminal cases. Two of the cases involved search and seizure issues. The third involved an issue of sufficiency of the evidence. 

The two search and seizure opinions were State v. Harper, 2014-Ohio-347, released on February 3, 2014, and State v. Horvath, 2014-Ohio-641 released on February 24, 2014. 

In the Harper opinion the appellate court reversed the Medina County Court of Common Pleas that had ruled that a traffic stop was based on a reasonable and articulable suspicion and that the Ohio Highway Patrol Trooper making the stop had conducted a valid inventory search. The appellate court disagreed with both of those conclusions. Since the State had introduced evidence seized from Ms. Harper's car at her trial for drug possession her conviction was reversed and the case was remanded. On remand the State moved to dismiss the charge since it could not sustain its burden of proof without the seized evidence. 

In the Horvath opinion the appellate court also reversed the trial court, but in that case the reversal was of the granting of a motion to suppress by the Medina Municipal Court. In Horvath the Medina Municipal Court had ruled that weaving by a motorist within his or her own lane does not constitute a traffic violation and therefore cannot lead to a traffic stop. 

The appellate court held that the case should be remanded to the trial court for that court to determine whether, given the particular facts of the case, Horvath's weaving raised a reasonable suspicion that his operation was impaired. 

State v. Lewis, 2014-Ohio-642, released on February 24, 2014,  concerned the issue of whether the evidence introduced in the Medina County Common Pleas Court was sufficient to sustain a conviction for domestic violence. The appellate court held that it was and affirmed Lewis's conviction, which had resulted in a 10 month prison sentence.