State v. Robinette

[This opinion has been published in Ohio Official Reports at 80 Ohio St.3d 234.] THE STATE OF OHIO, APPELLANT, v. ROBINETTE, APPELLEE. [Cite as State v. Robinette (1997), 80 Ohio St.3d 234.] Criminal law—Motor vehicles—Continued detention of a person stopped for a traffic violation constitutes an illegal seizure, when—Totality-of-the- circumstances test is controlling in an unlawful detention to determine whether permission to search a vehicle is voluntary—Requirements for consent to be considered an independent act of free will. 1. When a police officer’s objective justification to continue…