The Ohio Court of Appeals recently issued a ruling in the case of State v. Impson, affirming part of the trial court's decision while reversing the suppression of evidence related to field sobriety tests. The case, which involves a conviction for operating a vehicle under the influence (OVI), highlights important issues regarding traffic stops and the admissibility of evidence in DUI cases.
Joseph W. Impson, the appellant, faced charges stemming from a traffic stop initiated by Officer Michaela Colby of the Greenville City Police Department on February 18, 2025. Officer Colby stopped Impson's vehicle due to a malfunctioning license plate light. Upon approaching the vehicle, she detected a strong odor of alcohol and observed signs of impairment, including bloodshot eyes and slurred speech. Impson was subsequently arrested for OVI and failure to have a working license plate light.
The case reached the Ohio Court of Appeals after Impson's conviction in the Darke County Municipal Court. He filed a motion to suppress evidence obtained during the traffic stop, arguing that Officer Colby lacked reasonable suspicion to conduct the stop and that the field sobriety tests did not comply with established guidelines. The trial court denied the motion, leading to Impson's appeal.
During the appeal, the court reviewed the circumstances surrounding the traffic stop and the subsequent field sobriety tests. The court found that Officer Colby had sufficient grounds to initiate the stop based on the malfunctioning license plate light. However, the court also scrutinized the administration of the Horizontal Gaze Nystagmus (HGN) test, which is a common field sobriety test used to assess impairment.
The court ruled that the trial court erred in denying Impson's motion to suppress the results of the HGN test. According to the opinion, "The burden was on the State to show by clear and convincing evidence that the field sobriety test was performed in substantial compliance with the NHTSA Manual." The court noted that Officer Colby failed to follow proper procedures during the test, which included not holding the stimulus for the required duration and allowing distractions that affected the test's integrity.
As a result, the court reversed the trial court's decision regarding the HGN test results, stating, "The State did not present clear and convincing evidence that Officer Colby administered the tests in substantial compliance with the NHTSA standards." This ruling means that the results of the HGN test cannot be used in a new trial for Impson's OVI charge.
In terms of the impact of this ruling, it underscores the importance of law enforcement adhering to established protocols when conducting field sobriety tests. The court's decision to reverse the suppression of the HGN test results could set a precedent for future cases involving the admissibility of evidence obtained during DUI stops. It highlights the necessity for police officers to follow guidelines closely to ensure that evidence is valid and admissible in court.
Moving forward, Impson's case will be remanded to the trial court for further proceedings consistent with the appellate court's opinion. This means that Impson will have the opportunity for a new trial without the HGN test results being presented as evidence. The trial court will need to reevaluate the evidence and determine whether sufficient grounds exist to support a conviction for OVI based solely on the remaining evidence.
As of now, it is unclear whether the prosecution will appeal the court's decision or if there are any related cases pending that could affect this ruling. The outcome of Impson's new trial will depend on how the trial court assesses the remaining evidence without the HGN test results. This case serves as a reminder of the complexities involved in DUI cases and the critical role that procedural compliance plays in ensuring fair trials.