State v. Bobo

In State v. Bobo (1988), 37 Ohio St.3d 177, 524 N.E.2d 489, the Ohio Supreme Court determined that the officers in question had reasonable suspicion to conduct an investigatory stop based upon a combination of factors, each with a possibly innocent explanation." State v. Davison, 9th Dist. No. 21825, 2004 Ohio 3251, at P7, citing Bobo, at 179-80. Among the factors the Bobo court deemed sufficient to create a "reasonable suspicion of criminal activity" were "the reputation of an area for criminal activity, coupled with the time of day, the experience level of the officers involved, their knowledge of how drug transactions occur, suspicious gestures or movements by occupants of a vehicle, and the officers' experience as to what such movements mean." Id.