Brown v. Texas

When the defendant was stopped by the officers for the purpose of obtaining his identity, he was “seized” within the meaning of the Fourth Amendment. Whether this seizure was reasonable depends on a balancing between society’s interest and an individual’s interest in being free from random interference by law enforcement officers. In order for an investigatory stop to be lawful, the officer must have reasonable suspicion, based on articulable facts, that the suspect is involved in criminal activity. Here, the officers did not have reasonable suspicion. While the defendant may have “looked suspicious,” the officers could not articulate facts to support this conclusion. The officer conceded that the purpose of the stop was simply to ascertain the defendant’s identity. Standing alone, the fact that the defendant was in a drug trafficking area is insufficient to conclude he was engaged in criminal conduct. Because the stop was unlawful, application of the Texas statute to these facts was unconstitutional.