Reasonable Suspicion

Reasonable Suspicion

1. Nervous or Evasive Behavior

   • Wardlow’s sudden flight was considered evasive behavior. Evasive actions can indicate a person is trying to avoid law enforcement detection.

2. Officer Experience

   • The officers were assigned to a narcotics detail and had experience working drug-heavy areas. Their training allowed them to interpret Wardlow’s actions as suspicious.

3. Specific and Articulable Facts

   • Officers observed: • High crime location • Wardlow holding a bag • unprovoked flight

4. Totality of the Circumstances

   • The Court emphasized that reasonable suspicion is determined by looking at all factors together. No single factor justified the stop, but combined they created reasonable suspicion.

5. Flight

   • When Wardlow saw the police caravan, he immediately fled. The Court ruled that unprovoked flight upon seeing police is suggestive of wrongdoing and supports reasonable suspicion.

6. Presence Plus Additional Suspicious Conduct

   • Being present in a high crime area is not enough alone. However, presence plus sudden flight created lawful grounds for a Terry stop.

7. Criminal Activity

   • Officers suspected possible narcotics activity. Wardlow was holding an opaque bag in an area known for drug trafficking. The Court held police only need reasonable suspicion that criminal activity may be occurring, not proof.

8. High Crime Area

   • Wardlow was in an area known for heavy drug trafficking. The Supreme Court stated that being in a high crime area alone is not enough, but it is a relevant factor when combined with other suspicious behavior.

9. Illinois v. Wardlow (2000)