Bradley v. Reno

Ohio State Trooper Reno noticed a tractor-trailer stopped on the shoulder of the ramp connecting Route 46 to I-80. Worried that the truck posed a safety hazard, Reno approached and noticed that the engine was running and that no one appeared to be in the cab. Reno knocked on the truck door and, after a few minutes, Bradley emerged from the sleeper area of the cab. As he spoke to Bradley, Reno noticed that Bradley’s breath smelled of alcohol, his eyes appeared red and glassy, and his speech was slurred. When asked, Bradley admitted that he had consumed a “couple” “small pitchers” of beer and a “couple” bottles of beer an hour or two earlier at a truck stop 15 miles away. Bradley stated that he had parked on the shoulder to sleep, but he could not explain why he had stopped on the ramp rather than at a rest stop 200–300 feet away. Bradley failed two field sobriety tests and was swaying, losing his balance and failing to follow basic instructions. Reno arrested Bradley. A breathalyzer test at the Highway Patrol office confirmed that Bradley’s blood-alcohol content (.111%) exceeded the Ohio limit for commercial drivers (.04%). Denying a motion to suppress, the state court found that Reno had probable cause to arrest Bradley, but a jury acquitted Bradley. Invoking 42 U.S.C. 1983, Bradley sued. The district court awarded the defendants summary judgment, finding that the state court’s ruling precluded Bradley from relitigating probable cause. The Sixth Circuit vacated, finding that issue preclusion did not bar the suit. View "Bradley v. Reno" on Justia Law