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Illinois v. Wardlow


The defendant fled upon seeing a caravan of police vehicles converge on an area known for heavy narcotics trafficking. Seeing the defendant run, officers pursued him. They caught the defendant and conducted a frisk. The officers testified that in their experience there were usually weapons near narcotics transactions. They discovered a handgun on the defendant and arrested him.


Whether the officers had reasonable suspicion to stop the defendant?


Yes. Based on the type of area the officers were approaching and the behavior of the suspect, the officers established reasonable suspicion.


Where officers have a reasonable, articulable suspicion that criminal activity is afoot, they may conduct a brief, investigatory stop. There must exist at least a minimal level of objective justification for the stop. The Court held that an individual’s presence in a “high crime area,” standing alone, is not enough to support reasonable suspicion. However, a location’s characteristics are worthy of evaluation. When coupled with the defendant’s unprovoked flight, the officers’ aroused suspicion became reasonable. An individual has a right to ignore officers and go about his business. However, the Court stated that unprovoked flight is the exact opposite of “going about one’s business.”


528 U.S. 119, 120 S. Ct. 673 (2000)

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