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Illinois v. Wardlow

United States Supreme Court

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

      In Illinois v. Wardlow a caravan of four police vehicles, converged on to an area known for heavy narcotics trafficking, and the officers anticipated encountering a large number of people in the area, including drug customers and individuals serving as lookouts. As the caravan passed the area where defendant Wardlow was standing and holding an opaque bag, Wardlow looked in the direction of the officers and fled. It was at that moment, the United States Supreme Court held, that that officers were justified in suspecting that Wardlow was involved in criminal activity, and were permitted to stop him and investigate further.

     The U.S. Supreme Court though would not adopt a bright-line rule authorizing the temporary detention of just anyone who flees at the mere sight of a police officer. That the threshold would still need to add up to reasonable suspicion which would be needed to support such a detention. The Terry Stop would be determined by looking at the totality of the circumstances-the whole picture of what occurred.

     The court explained that an individuals presence in an area of expected criminal activity, standing alone, is not enough to support a reasonable particularized suspicion that the person is committing a crime. But in the same token, officers are not obligated to ignore relevant characteristics of a location in determining whether the circumstances are sufficiently suspicious to allow further investigation.

     In this case it was not simply Wardlows presence in an area of heavy drug dealing that aroused the officers suspicion but his unprovoked flight upon noticing the police. And an officer developing a reasonable articulable suspicion, nervous, evasive behavior may be considered as a major factor in the equation. 

     The court stated: Headlong flight-wherever it occurs-is the consummate act of evasion: it is not necessarily indicative of wrongdoing, but it is certainly suggestive of such. In reviewing the propriety of an officers conduct, courts do not have available empirical studies dealing with inferences drawn from suspicious behavior, and we cannot reasonably demand scientific certainty from judges or law enforcement officers where none exists.

United States v. Green

United States Court of Appeals

670 F.2d. 1148 (D.C. Cir. 1981)

     Officer Allman, an experienced member of the 3rd District Drug Enforcement Unit of the Washington D.C. Metropolitan Police Department was stationed in an undisclosed observation point investigating narcotics activity at the intersection of 14th and V Streets, N.W. This Neighborhood is known as a high crime area, which is used as stomping ground for drug trafficking. At about 11:25 a.m., Officer Allman observed, with the aid of binoculars, three individuals: a man which was later identified as the defendant, Gary Green; a woman who was later identified as Carol Turner; and an unidentified man on the southwest corner of the intersection. During this time Officer Allman observed the unidentified man approach Ms. Turner, engage in a brief conversation then hand her some paper currency. Turner then walked several feet to Green and handed him the money. Green took the money, stuffed it in his left pant pocket, reached into a paper bag, which was in his left jacket pocket, and appeared to hand a small object from the bag to Turner. Officer Allman was unable to see the exchanged object, which was concealed, in Greens cupped hand and then in Turners hand. Turner returned to the unidentified man and handed him the object. The unidentified man then received the object and left the area. Officer Allman then saw Green push the top of the brown paper bag back into his left jacket pocket, concealing it from view. Believing that he has just witnessed a typical two-party drug transaction, Officer Allman radioed the descriptions of Green and Turner to officers awaiting his instructions in an unmarked patrol car two blocks away. Those officers drove to the intersection of 14th and V Street and Officer Willis spotted Green from Officer Allmans description. Green recognizing the unmarked patrol car or the officers as they approached, walked quickly into a restaurant, looking back over his shoulder at Officer Willis, who had left the unmarked car to pursue Green on foot. Officer Willis saw Green open the restaurant door with his left hand, move five or six feet inside the restaurant, motion with his right hand, and then start to move back out the door. Officer Willis found a brown paper bag lying on the unoccupied counter inside the restaurant, only three to five feet away from Greens position at the time of the confrontation with officer Willis. The paper bag was within Greens reach and could have been placed on the counter by the movement of Greens right hand that Officer Willis had observed just before Green started out of the restaurant. Officer Willis looked in the brown paper bag and discovered fourteen small packets of heroin. A search of Greens person revealed $242.00, which was subsequently seized as a result of the above listed events.

     The court in this case identified three factors, especially when observed by experienced police officers in an area noted for the regularity of narcotics trafficking, provided probable cause for arrest. Id. at 1151. The court noted the following factors:

 1.      The sequence of events between the three parties, Green, Turner, and the unidentified man, which clearly exhibited a two-party drug transaction.

2.      The movement of the three persons cupped hands and Greens actions of stuffing the paper bag back into his jacket pocket, which lead the officers to believe that they were attempting to conceal the object of their transaction;

3.      And, the observation officer Willis possessed that Green was attempting to flee when pursued. 

     The court explained though individually these observations would not establish probable cause, but only the totality of the circumstances approach using all the elements observed, would bring an officer, based on his training, knowledge and experience, to this level of probable cause.

     The court further explained what probable cause meant in a situation such as this when making a determination:

"Probable cause exists if the totality of the circumstances, as viewed by a reasonable and prudent police officer in light of his training and experience, would lead that police officer to believe that a criminal offense has been or is being committed."

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