A Euclid police officer did not violate a motorist’s constitutional rights when the officer stopped the driver for suspicion of being involved in an armed robbery, but also stopped him for a suspected window tint violation, the Supreme Court of Ohio ruled today.

In a 6-1 decision, the Supreme Court reversed an Eighth District Court of Appeals decision suppressing the evidence discovered during the traffic stop that led to a weapons charge against the driver, Rasheed Mathis. The Eighth District upheld a trial court ruling that found the officer noticed the window tint violation, but stopped Mathis for the purpose of investigating the earlier armed robbery. Once Mathis had been pulled over, the officer quickly ruled him out as a suspect in the robbery.

Writing for the Court majority, Justice Daniel R. Hawkins stated the officer immediately recognized a window tint violation of Mathis’ van when he saw it drive by. The officer had also heard the department was on the lookout for a similar van. Once the officer learned the van was not used in the robbery, the officer did not have to abandon his investigation of Mathis’ suspected window-tint violation, the Court ruled.

“We conclude that the officer need not end his investigation if the traffic stop remains justified by a basis for reasonable suspicion that is independent from the extinguished basis,” Justice Hawkins wrote.

Chief Justice Sharon L. Kennedy and Justices Patrick F. Fischer, R. Patrick DeWine, Joseph T. Deters, and Megan E. Shanahan joined Justice Hawkins’ opinion.

Justice Jennifer Brunner dissented without a written opinion and stated that she would dismiss the appeal as improvidently accepted.

Window Tint, License Plate Prompt Police Stop
In January 2023, Euclid police received a report of an armed robbery. The suspect’s vehicle was either a gold or tan Dodge or Chrysler minivan with a license plate possibly beginning with “TWL.”

Two days after the robbery, a police officer who had been advised of the robbery saw Mathis driving a light blue Chrysler minivan with a license plate beginning with “JWL.” The officer would later testify that the original reason he stopped Mathis was that the van’s windows appeared to exceed the legal amount of window tint. When the officer drove closer to the vehicle, he realized that it possibly matched the armed robbery suspect’s van.

After pulling Mathis over, and before speaking to him, the officer noticed the paint color and license plate did not exactly match the robbery description. He continued the stop, and, while speaking to Mathis, he and a fellow officer smelled burnt marijuana coming from the minivan. The other officer also saw burnt marijuana in the vehicle. The officers asked Mathis to step out and frisked him. Mathis, a convicted felon, had a loaded gun in his pocket.

Suspect Challenges Search
Mathis was charged with multiple crimes based on possessing the firearm. He asked the trial court to suppress the evidence from the stop. He argued that once the officer realized his vehicle did not match the description of the van used in the armed robbery, the officer should have ended the traffic stop.

The trial court judge conducted a hearing and stated the traffic stop was not about the tinted windows but was to investigate the armed robbery. Based on that finding, the officer should have stopped the search once he concluded the van did not match the one used in the robbery, the judge ruled. The Cuyahoga County Prosecutor’s Office appealed the decision to the Eighth District. The appeals court affirmed the trial court’s decision, and the prosecutor appealed to the Supreme Court.

Supreme Court Examined Search Requirements
Under the Fourth Amendment to the U.S. Constitution, the Court examines whether a traffic stop is lawful by determining whether the officer had reasonable suspicion that the motorist had committed or was committing a criminal violation, the opinion stated.

Citing the Court’s 1996 Dayton v. Erickson decision, Justice Hawkins explained the Court does not consider whether “the officer had some ulterior motive for making the stop, such as a suspicion that the violator was engaging in more nefarious activity.” Rather, the Court looks at the circumstances objectively and determines whether the stop was reasonable based on the facts and circumstances known to the officer at the time of the stop, the opinion stated.

The officer testified at the suppression hearing that he immediately noticed the dark tinted windows and had made hundreds of traffic stops involving window tint violations. He tested Mathis’ windows and found the tint was about four times darker than the legal limit.  While the officer could not have known the precise amount of excessive window tint at the time he initiated the traffic stop, his experience and training allowed him to make an informed decision, the opinion noted.

Objectively viewing the facts and circumstances, the officer did have reasonable suspicion to believe Mathis was violating a traffic law and could be stopped, the Court concluded. The trial court mistakenly based its decision on the officer’s motivation for the stop, the opinion stated.

“Irrespective of whether the officer’s reason for pulling Mathis over was or was not about tinted windows, the officer possessed – at minimum – a reasonable articulable suspicion that Mathis was violating a traffic law,” the opinion stated.

The fact that the officer may have primarily stopped Mathis to investigate the armed robbery does not affect the fact that the officer also knew Mathis’ windows were too dark, the Court stated. The officer’s suspicions about the license plate and vehicle color were dispelled when he walked up to it, but that did not impact his suspicion of a window tint violation, the opinion explained. He was not required to abandon the traffic stop, and the trial court should not have suppressed the evidence, the Court ruled.

The Court remanded the case to the trial court for further proceedings.

2025-0091. State v. Mathis, Slip Opinion No. 2026-Ohio-2269.

View oral argument video of this case.

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