In State v. Schott (May 16, 1997), 2d Dist. No. 1415, 1997 Ohio App, the officer approached the defendant's car, which was stopped in a "no parking" zone, to inform him he was not permitted to park in that area. When he approached the driver, the officer noticed a strong odor of alcohol. As a result, the officer required the defendant to submit to field sobriety tests. Based on his poor performance on the tests, the officer concluded the defendant was intoxicated and he therefore arrested him for driving under the influence of alcohol. The Second District held that while a strong odor of alcohol is insufficient to give rise to probable cause, the "strong odor of alcohol was sufficient to provide the police officer with reasonable suspicion that Schott was driving with a blood alcohol level that exceeded the legal limit. The police officer was therefore permitted to subject Schott to field sobriety tests." Id. at 13.