The Ohio Court of Appeals has issued a ruling on the appeal of Joseph W. Impson, who was convicted of operating a vehicle under the influence (OVI) and related charges. The court's decision, filed on October 23, 2026, in case number 2025-CA-21, both affirms and reverses parts of the trial court's judgment, significantly impacting Impson's legal standing and future proceedings.
This case began with 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. After conducting field sobriety tests, Impson was arrested for OVI and charged with a first-degree misdemeanor.
Impson contested the charges, claiming that the evidence obtained during the traffic stop should be suppressed. He argued that Officer Colby lacked reasonable suspicion for the stop and did not comply with the proper procedures for administering the Horizontal Gaze Nystagmus (HGN) test, a common field sobriety test. This dispute led to a motion to suppress evidence, which the trial court ultimately denied.
The appellate court's ruling addressed several key issues raised by Impson. The court found that while the trial court erred in requiring Impson to present evidence first at the suppression hearing, this did not affect his substantial rights. The court stated, "The record before us does not establish that Impson’s substantial rights were affected by the order in which evidence was presented at the hearing."
However, the court also determined that the trial court should have granted Impson's motion to suppress the results of the HGN test. The ruling noted that Officer Colby failed to adhere to the National Highway Traffic Safety Administration (NHTSA) guidelines during the test. The court emphasized, "There was insufficient evidence in the record to support the trial court’s finding that Officer Colby performed the HGN in substantial compliance with the NHTSA Manual." As a result, the court reversed the trial court's ruling regarding the HGN test and remanded the case for a new trial without the test's results.
The impact of this ruling is significant for Impson and similar cases in Ohio. The court's decision reinforces the importance of following established protocols during field sobriety tests. Law enforcement officers must demonstrate substantial compliance with NHTSA guidelines to use the results of such tests in court. This ruling could affect future OVI cases, as it sets a precedent regarding the admissibility of field sobriety test results.
Moving forward, Impson's case will return to the trial court for further proceedings, where the state will not be able to introduce the results of the HGN test. However, the court clarified that officers could still testify about their observations of Impson during the traffic stop, which may include signs of impairment unrelated to the HGN test.
Impson's legal team is expected to prepare for the new trial, where the prosecution will need to rely on other evidence to prove the OVI charge. The outcome of this case may influence how law enforcement conducts future traffic stops and sobriety tests, ensuring that proper procedures are followed to uphold the rights of individuals involved.
Details were not available in the court filing regarding whether Impson plans to appeal further or if there are related cases pending. However, the ruling serves as a reminder of the critical balance between enforcing traffic laws and protecting individual rights.