A police officer may extend a lawfully initiated traffic stop to investigate the status of a driver’s license even after the reason for initiating the stop is dispelled, the Supreme Court of Ohio ruled today.

A Supreme Court majority upheld the conviction of Quentin Fips, whom officers stopped in December 2018 after observing him driving with only one functioning headlight.  After initiating the stop and obtaining Fips’s information, the officers discovered that they might have been mistaken about his headlight. The traffic stop nevertheless continued, and the officers discovered that Fips was driving without a valid license and that he had an outstanding warrant. Acting on this information, the officers arrested Fips. A subsequent search of his car revealed crack cocaine and a digital scale.

Fips was charged with two drug-related crimes. He asked the Cuyahoga County Common Pleas Court to suppress the evidence, arguing that once police learned his headlights were working, they had no right to prolong the stop to inquire about his license. The court rejected the argument and denied Fips’s motion to suppress the evidence. Fips pleaded no contest to the charges and was sentenced to five years in prison.

The Eighth District Court of Appeals vacated his convictions, finding the search was illegal. Today’s Supreme Court decision reversed the Eighth District’s ruling.

Writing for the Court majority, Justice Joseph T. Deters explained that the majority based its decision on two grounds. Under U.S. Supreme Court precedent , an officer can investigate the status of a driver’s license even if the reasonable suspicion that was the reason for the stop is dispelled. Second, if a driver fails to provide a license, an officer has a new reasonable suspicion of a crime to justify an investigation.

“When an officer discovers facts during a traffic stop that give rise to a reasonable suspicion of criminal activity, the officer may extend the traffic stop to investigate. This is so even if the suspected criminal activity is ‘beyond that which prompted the initial stop,’” Justice Deters wrote, citing the Court’s 2007 State v. Batchili decision.

Justices R. Patrick DeWine, Jennifer Brunner, Daniel R. Hawkins, and Megan E. Shanahan joined the opinion written by Justice Deters. Justice Patrick F. Fischer dissented and stated he would dismiss the appeal as having been improvidently accepted.

In a concurring opinion, Chief Justice Sharon L. Kennedy stated that Fips’s constitutional rights were not violated because the investigating officer “had an unbroken chain of reasonable suspicion throughout the traffic stop.” However, she opined that the majority erred in adopting the Court’s lead opinion in its 2024 State v. Dunlap decision because the facts in that case greatly differ from Fips’s case.

She noted that in Dunlap, there was a period during the traffic stop when the officer had no reasonable suspicion of criminal activity and consequently no reason for prolonging the stop to inquire about the driver’s licensing status. This case is different, according to the chief justice, because the officer had a reasonable suspicion that a crime had been committed throughout the stop since Fips did not produce a driver’s license before the officer realized the mistake about the headlight.

Driver Questioned After Traffic Stop
Linndale Police Officer Garron Rose stopped Fips, believing he observed Fips driving with one working headlight. Rose was accompanied by a trainee officer. Rose, who was wearing a body camera that recorded his encounter with Fips, told Fips he was stopped for a nonworking headlight and asked for his driver’s license. Fips replied that he did not have his license with him and gave Rose his name, date of birth, and Social Security number.

While Rose was speaking to Fips, the trainee officer checked the front of the car and found that the headlights were working, but one fog light was out. Less than a minute after learning the headlight might be working, Rose provided police dispatch with Fips’s Social Security number and learned that Fips had failed to reinstate his license and had an outstanding arrest warrant.

Based on the information, Rose arrested Fips. A search of the vehicle led to the discovery of cocaine and a scale. Fips was indicted on felony counts of drug trafficking and drug possession.

Driver Sought to Prevent Use of Evidence
Fips asked the trial court to suppress the evidence seized during the traffic stop, arguing that Rose did not have reasonable suspicion to stop the car because both headlights were working at the time. The trial court denied Fips’s motion, and he pleaded no contest to the charges.

Fips appealed to the Eighth District, and the three-judge panel issued three separate opinions . Two judges found the evidence should be suppressed and reversed the trial court’s decision. The Cuyahoga County Prosecutor’s Office appealed the case to the Supreme Court.

Supreme Court Analyzed Traffic Stop Search Procedures
The Fourth Amendment to the U.S. Constitution prohibits unreasonable searches and seizures, and a traffic stop constitutes a seizure, Justice Deters explained. To comply with the Fourth Amendment, an officer must have “reasonable and articulable suspicion” that a motorist committed, is committing, or is about to commit a crime to make a traffic stop.

Fips did not dispute that the initial stop, based on the belief that the headlight was out, was lawful, the opinion stated. However, he disputed the police's right to extend the traffic stop once the officers discovered that they were mistaken about the headlight. Fips argued that once Rose’s initial suspicion about the nonworking headlight was dispelled, the officer did not have the right to verify his driver’s license status.

The prosecutor urged the Court to adopt the lead opinion in Dunlap, which was joined by three justices. That opinion held that an officer may complete the mission of a lawfully initiated traffic stop, including verifying the driver’s identity and license status, even after the reason for the initial stop is resolved.  The Dunlap decision incorporates a portion of the U.S. Supreme Court’s 2015 Rodriguez v. United States ruling, which found that part of a traffic stop’s mission is to confirm that the driver is validly licensed.

In today’s opinion, a majority of the court decided to “adopt Dunlap’s reading of Rodriguez.”  Citing Dunlap, Justice Deters explained that “once a traffic stop has been validly initiated, an officer is entitled to complete the mission of the stop,” which includes confirming that a driver is validly licensed, “even after the initial reasonable suspicion has been dispelled.”  Thus, Rose was entitled to complete the mission of the stop by checking Fips’s license status even after determining both headlights were working, the opinion stated.

The extension of the stop was also justified by Rose’s newly developed suspicion of a crime when Fips could not produce a driver’s license. Rose could “reasonably infer from this information” that Fips might not have a valid driver’s license, and driving a car without a valid license is a crime, the opinion noted.

The Court noted that Fips raised additional arguments in his appeal to the Eighth District contesting his conviction. The Court remanded the case to the appeals court for further proceedings to address Fips’s unresolved assignments of error.

2023-1001. State v. Fips, Slip Opinion No. 2026-Ohio-1207.

View oral argument video of this case.

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