State v. Wooten

In State v. Wooten, Athens App. No. 01CA31, 2002 Ohio 1466, the Court noted that the Due Process Clause does not require the state to employ a particular investigative tool. Id., citing Youngblood, 488 U.S. at 59. The Court later noted that the state "has no constitutional duty to ensure that OVI defendants' traffic stops and sobriety tests are recorded on video or audio tape." Wooten . Ultimately, we concluded that "because no constitutional violation arises merely from a law enforcement officer's failure to employ a particular investigative tool, the suppression of evidence or the dismissal of a charge is not warranted." Id.