State v. Rhude

In State v. Rhude (1993), 91 Ohio App.3d 623, 632 N.E.2d 1391, an officer stopped a vehicle that drove down a lane, back out onto the road, and then parked in a driveway. Id. at 625. The reports were of "prowlers and burglaries" in the area, but the officer "did not observe the suspect operating his vehicle in an impaired or erratic manner or violating any traffic laws." Id. The Rhude court held that these facts were not sufficient to show reasonable suspicion. Id. at 626.