Not according to the Eighth District.
Would the Supreme Court of Ohio Agree?
That the officer may have stopped Mr. Mathis primarily to investigate the earlier armed robbery does not affect the fact that the officer also possessed, before initiating the traffic stop, independent reasonable suspicion that the window tint on Mr. Mathis’s vehicle was too dark.
State v. Mathis
Supreme Court of Ohio
June 18, 2026
Why is this case important?
State v. Mathis reassures officers that they are not required to terminate a lawful traffic stop the moment one suspicion disappears, provided another independent legal justification remains – otherwise known as a Pre-Textual traffic stop. Mathis also serves as a reminder that officers should carefully articulate every objective fact supporting the initial stop and any additional reasonable suspicion, as those additional factors, not the officer’s motives, will determine whether the stop is Objectively Reasonable.
Background
The Euclid Police Department received a report of an armed robbery, with the suspect’s vehicle described as a gold or tan Dodge or Chrysler minivan with a license plate possibly beginning with “TWL.”. Two days after the armed robbery, a Euclid police officer who had been advised of the armed robbery initiated a traffic stop on appellee, Rasheed Mathis, who was driving a light blue Chrysler minivan with the license plate “JWL 5635.” The officer later testified that he had originally decided to initiate the stop of the vehicle because its windows appeared to him to be illegally tinted. The officer also testified that as he drove closer to Mr. Mathis’s vehicle to initiate the traffic stop, he realized that it possibly matched the vehicle described in the armed-robbery report.
Wrong Robbery Vehicle – Right Window Tint, Weed and WUD Vehicle
After pulling Mr. Mathis’s vehicle over, the officer approached it on foot and noticed—before speaking to Mr. Mathis—that the paint color and license plate did not exactly match the vehicle described in the armed-robbery report. The officer nevertheless continued the traffic stop, and during the stop, he and his partner smelled burnt marijuana coming from the vehicle and his partner saw burnt marijuana inside the vehicle. The officers then asked Mr. Mathis to step out of the vehicle, frisked him, and discovered that Mr. Mathis—a convicted felon—had a loaded firearm in one of his pockets.
Trial Court Suppressed the Firearm
Mr. Mathis filed a motion to suppress after he was charged with multiple crimes based on his possession of the firearm. He argued that once the officer realized that Mr. Mathis’s vehicle did not match the description of the vehicle described in the armed-robbery report, the officer should have ended the traffic stop. The trial court held a suppression hearing, and it subsequently issued a journal entry granting the motion to suppress. It did not, however, state on the record its findings of fact.
Eighth District Remands back to Trial Court
The State filed an appeal in the Eighth District and filed a motion in that court requesting an order directing the trial court to state its findings of fact on the record. The Eighth District granted the State’s motion and remanded the case to the trial court.
Trial Court Again Suppresses the Firearm
At a hearing held after remand, the trial court stated its finding that the traffic stop “wasn’t about tinted windows” but was instead performed to investigate the armed robbery. Based on that finding, the trial court concluded that the investigation “should have stopped” as soon as the police officer determined that Mr. Mathis’s vehicle did not match the vehicle described in the armed-robbery report.
Eighth District Upholds Trial Court Suppression of the Firearm
The State appealed for a second time, and the Eighth District affirmed the trial court’s judgment, holding that “the police improperly extended the stop even after they no longer had a reasonable suspicion to detain Mr. Mathis.” 2024-Ohio- 5707, ¶ 33 (8th Dist.). We accepted the State’s appeal to review the following proposition of law:
Was this a Valid Traffic Stop?
When officers are confronted with evidence of a crime during a valid traffic stop, they are not required to abandon the investigation of that crime simply because the crime may be unrelated to the initial purpose of the stop. See 2025-Ohio-1090.
Established Case Law – Traffic Stops
The Fourth Amendment guarantees the right of the people to be free from unreasonable searches and seizures. An investigatory traffic stop by a law- enforcement officer is a “seizure” of the vehicle’s occupants and must therefore “be conducted in accordance with the Fourth Amendment. ” Heien v. North Carolina, 574 U.S. 54, 60 (2014), citing Brendlin v. California, 551 U.S. 249, 255-259 (2007). In determining whether a traffic stop was lawful, we ask whether the officer had reasonable suspicion that the motorist had committed or was committing a criminal violation, including a traffic violation, State v. Mays, 2008-Ohio 4539, ¶ 7, citing Delaware v. Prouse, 440 U.S. 648, 663 (1979), and Berkemer v. McCarty, 468 U.S. 420, 439 (1984). An officer has reasonable suspicion to conduct a traffic stop when the officer has “‘a particularized and objective basis for suspecting’” that a motorist has violated the law, Navarette v. California, 572 U.S. 393, 396 (2014), quoting United States v. Cortez, 449 U.S. 411, 417-418 (1981).
Eighth District Gets Schooled on 1996 Case Law
Determining whether a traffic stop was reasonable under the Fourth Amendment involves an objective inquiry. See Heien at 66. This means that we do not consider “the actual motivations of the individual officers involved.” Whren v. United States, 517 U.S. 806, 813 (1996). When determining whether a traffic stop is reasonable, we do 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 criminal activity,” Dayton v. Erickson, 1996-Ohio-431, syllabus. We ask instead “whether ‘the circumstances, viewed objectively, justify [the challenged] action.’” (Bracketed text in original.) Ashcroft v. al-Kidd, 563 U.S. 731, 736 (2011), quoting Scott v. United States, 436 U.S. 128, 138 (1978); see also Erickson at ¶ 8 (whether a traffic stop is lawful depends on the facts and circumstances known to the officer at the time of the stop, “not upon the officer’s actual (subjective) state of mind”); Florida v. Jardines, 569 U.S. 1, 10 (2013) (“a stop or search that is objectively reasonable is not vitiated by the fact that the officer’s real reason for making the stop or search has nothing to do with the validating reason” [emphasis in original]).
[W]e readily conclude that the traffic stop here did not violate the Fourth Amendment.
Guided by these principles, we readily conclude that the traffic stop here did not violate the Fourth Amendment. The Euclid police officer testified at the suppression hearing that the dark window tint was the first thing that he observed about Mr. Mathis’s vehicle. He explained that based on his experience in handling hundreds of traffic stops involving window-tint violations, the windows on Mr. Mathis’s vehicle were “readily identifiable” to him as being too dark. A window- tint test performed on Mr. Mathis’s vehicle that night measured the light transmittance of the passenger-side window at 12 percent—approximately four times darker than the legal limit, see Adm.Code 4501-41-03(A)(3) (window tint on a motor vehicle that results in “a light transmittance of less than fifty per cent plus or minus three per cent” is unlawful); see also O.R.C. §4513.241(A) (authorizing the director of public safety to adopt rules governing the use of tinted glass in motor-vehicle windows), (C) (prohibiting a person from operating a motor vehicle on the roadway unless the vehicle conforms to the requirements of any rules adopted under O.R.C. §4513.241), and (K)(1) (classifying a violation of O.R.C. §4513.241(C) a minor misdemeanor). To be sure, the officer could not have known this precise light-transmittance percentage when he initiated the traffic stop, but his “experience and specialized training” allowed him “to make inferences from and deductions about” the information available to him, United States v. Martin, 289 F.3d 392, 398 (6th Cir. 2002). Viewed objectively, then, the facts and circumstances known to the officer when he initiated the traffic stop gave him, at minimum, “‘a particularized and objective basis for suspecting, ’” Navarette at 396, quoting Cortez at 417, that Mr. Mathis was violating a traffic law. See, e.g., United States v. Shelton, 817 Fed.Appx. 217, 219 (6th Cir. 2020) (officer with knowledge of window-tint law who observes a vehicle with tint substantially darker than permitted by law has reasonable suspicion to conduct a traffic stop); United States v. Shank, 543 F.3d 309, 313 (6th Cir. 2008) (same).
Trial Court Applies Irrelevant Factor Under the Fourth Amendment
The error of the trial court in this case comes from its determination that the officer’s motive for initiating the traffic stop was relevant to the Fourth Amendment analysis. The trial court made the factual finding that the traffic stop “wasn’t about tinted windows” but was instead about the earlier armed robbery. Based on this finding, it made the legal conclusion that the officer lacked reasonable suspicion to continue the traffic stop after discovering that Mr. Mathis’s vehicle did not match the vehicle described in the armed-robbery report. But that legal conclusion does not follow from the factual finding. Irrespective of whether the officer’s reason for pulling Mr. Mathis over was or was not about tinted windows, the officer possessed—at minimum—a reasonable articulable suspicion that Mr. Mathis was violating a traffic law. The officer’s testimony about what he saw on the night of the traffic stop was not challenged by Mr. Mathis, and the trial court did not find that the officer did not notice the tinted windows on Mr. Mathis’s vehicle. The finding of fact that was made by the trial court—the purpose of the traffic stop—went to the subjective intent of the officer, which is an irrelevant factor under a Fourth Amendment analysis.
Unforced Eighth District Error
The Eighth District furthered the error by failing to correct the trial court’s erroneous legal conclusion. The appellate court correctly noted that it was required to “defer to the trial court’s findings of fact if [those findings of fact] are supported by competent, credible evidence” because the trial court was in the “best position to analyze the evidence and evaluate the credibility of the witnesses.” 2024-Ohio-5707 at ¶ 24 (8th Dist.). It therefore adopted the trial court’s finding of fact that the officer “did not stop Mr. Mathis for a window-tint violation but rather to investigate him as a suspect in the earlier robbery.” Id. at ¶ 30. But the appellate court concluded that the officer “should have sent [Mr. Mathis] on his way,” id. at ¶ 32, when he discovered that Mr. Mathis’s vehicle did not precisely match the vehicle described in the armed-robbery report. This legal conclusion, again, does not follow from the finding of fact. That the officer may have stopped Mr. Mathis primarily to investigate the earlier armed robbery does not affect the fact that the officer also possessed, before initiating the traffic stop, independent reasonable suspicion that the window tint on Mr. Mathis’s vehicle was too dark. The officer’s discovery of the partial license-plate mismatch and minor paint-color discrepancy—even assuming that those differences were in fact enough to dispel the officer’s second source of reasonable suspicion—did not require the officer to abandon the traffic stop. Accordingly, we adopt the State’s sole proposition of law.
Supreme Court of Ohio Breaks No New Ground Applying a 1996 U.S. Supreme Court Case
It has long been recognized that an officer’s subjective intent does not factor into an analysis under the Fourth Amendment. See, e.g., Whren, 517 U.S. at 813; Erickson, 1996-Ohio-431, at syllabus. We break no new ground holding the same here.
Conclusion and Holding
The judgment of the Eighth District Court of Appeals is reversed, and the matter is remanded to the trial court for further proceedings consistent with this opinion.
Information for this article was obtained from State v. Mathis, 2026 – Ohio – 2269.
State v. Mathis, 2026 – Ohio – 2269 was issued on June 18, 2026 by the Supreme Court of Ohio and is binding throughout the State of Ohio.
Lessons Learned
Pre-Textual Stop – On June 10, 1996 the U.S. Supreme Court issued Whren v. U.S., 517 U.S. 806 (1996) and the court held “Here the District Court found that the officers had probable cause to believe that petitioners [Mr. Whren] had violated the traffic code. That rendered the stop reasonable under the Fourth Amendment, the evidence thereby discovered admissible.”.
This is commonly called a Pre-Textual Traffic Stop. If an officer has a gut feeling or a hunch that occupants of a vehicle are involved in a crime and that level of suspicion is less than reasonable suspicion, the officer may lawfully stop the vehicle if probable cause is established the driver committed a traffic violation or there is an equipment violation on the vehicle. In this case, the unidentified Euclid Police Officer observed a window tint violation and upon first approach smelled burnt marijuana. These factors identify that the officer had probable cause to believe that there was a window tint violation as the court explained “see Adm. Code 4501-41-03(A)(3) (window tint on a motor vehicle that results in “a light transmittance of less than fifty per cent plus or minus three per cent” is unlawful); see also O.R.C. §4513.241(A) (authorizing the director of public safety to adopt rules governing the use of tinted glass in motor-vehicle windows), (C) (prohibiting a person from operating a motor vehicle on the roadway unless the vehicle conforms to the requirements of any rules adopted under O.R.C. §4513.241), and (K)(1) (classifying a violation of O.R.C. §4513.241(C) a minor misdemeanor).”. Because the Euclide police officer observed the window tint violation the traffic stop was lawful.
Traffic Stop Legal Requirements – If the occupants of a vehicle are reasonably suspected of committing a crime, then the officer only needs reasonable suspicion to stop the vehicle. Terry v. Ohio, 392 U.S. 1 (1968). However, if an officer wants to stop a vehicle for an equipment or traffic violation the legal threshold is probable cause. In both cases, law enforcement will conduct a traffic stop with lights and siren to signal the vehicle to stop. However, the purpose of the stop will be evaluated by the courts. If the stop is investigatory because the officer reasonably suspects the occupants had or about to commit a crime, then if the suspicion is dispelled – the officer was wrong, the vehicle stop must conclude. The officer may still assure the driver is a licensed driver, see Can a Traffic Stop be Extended to Assure the Driver is Licensed? State v. Dunlap/Lewis, 2024 – Ohio – 4821. Conversely if the officer identifies an equipment or traffic violation the traffic stop AND all of the occupants may be detained for the reasonable amount of time to conclude the traffic stop. See Rodriguez v. U.S., 575 U.S. 348 (2015).
A Win for the Criminal Justice System – The fact that the Cuyahoga County trial judge and the Eighth District Appellate Court failed to apply Whren v. U.S., 517 U.S. 806 (1996) nearly left Cuyahoga County in trail of legal wreckage. The unidentified Euclid police officer conducted a textbook Pre-Textual traffic stop. The officer had a partial license plate of a similar vehicle involved in an armed robbery two days prior. This in and of itself would not rise to the level of reasonable suspicion to stop the vehicle because of the limited information and the two-day delay. However, the window tint violation was unclear to the Cuyahoga County trial court judge and the Eighth District Appellate Court. Fortunately, the Supreme Court of Ohio overturned the Eighth District in a six to one decision. The legal trek of this case is a prime example of how the criminal justice system is to work. The law enforcement officer made the correct legal decision, was told three times by two different courts [trial court and Eighth District Appellate Court] that he was wrong, only to be corrected by six judges on the Supreme Court of Ohio.
Pre-Sent Arms! The unidentified Euclid Police Officer and the Cuyahoga County Prosecutor’s Office should be highly commended for their investigation, prosecution and successful appeal. Well done!
Does your agency train on Investigative Detention?
Don’t fail your training.
Don’t let your training fail you!
Be safe, smart and objectively reasonable!