528 U.S. 119 (2000)
On September 9, 1995, Officers Nolan and Harvey were working as uniformed officers in the special operations section of the Chicago Police Department.1 The officers were driving the last car of a four-car caravan converging on an area known for heavy narcotics trafficking to investigate drug transactions.2 The officers were traveling together because they expected to find a crowd of people in the area, including lookouts and customers.3
As the caravan passed 4035 West Van Buren, Officer Nolan observed respondent Wardlow standing next to the building holding an opaque bag.4 Respondent looked in the direction of the officers and fled.5 Nolan and Harvey turned their car southbound, watched him as he ran through the gangway and an alley, and eventually cornered him on the street.6 Nolan then exited his car and stopped respondent.7 He immediately conducted a protective patdown search for weapons.8 During the frisk, Officer Nolan squeezed the bag respondent was carrying and felt a heavy, hard object similar to the shape of a gun.9 The officer then opened the bag and discovered a .38-caliber handgun with five live rounds of ammunition.10 The officers arrested Wardlow.11
The Illinois trial court denied respondent’s motion to suppress.12 Following a stipulated bench trial, Wardlow was convicted of unlawful use of a weapon by a felon.13 The Illinois Appellate Court reversed Wardlow’s conviction.14 The Illinois Supreme Court affirmed the reversal.15
The United States Supreme Court granted certiorari.16
Whether the initial stop was supported by reasonable suspicion?17
Under Terry v. Ohio, an officer may conduct a brief investigatory stop when the officer has a reasonable, articulable suspicion that criminal activity is afoot.18 Reasonable suspicion requires a minimal level of objective justification and is based on the totality of the circumstances, including commonsense judgments about human behavior.19 Presence in a high-crime area and unprovoked flight upon noticing police are relevant factors that together can support reasonable suspicion.20
Yes. The officers were driving the last car of a four-car caravan converging on an area known for heavy narcotics trafficking when Officer Nolan observed Wardlow standing next to the building holding an opaque bag.21 Wardlow looked in the direction of the officers and fled unprovoked.22 This combination of factors, with the location adding relevant context and the headlong flight serving as the consummate act of evasion, supplied the minimal objective justification required under the reasonable suspicion standard.23
The stop therefore complied with the Fourth Amendment.24
The initial stop was supported by reasonable suspicion.25
Related opinions on this issue
Justice Stevens agreed that the Court correctly rejected both proposed per se rules, one authorizing stops based solely on unprovoked flight and the other prohibiting them, because the inference from flight depends on the totality of the circumstances and commonsense conclusions about human behavior.26 He emphasized that flight can occur for entirely innocent reasons, such as seeking shelter or avoiding contact, and that in high crime areas many residents may flee due to fear of police contact itself.27 Applying the totality test to the facts, however, Stevens concluded that Officer Nolan's terse testimony failed to establish reasonable suspicion because it did not show whether Wardlow recognized the officers, whether the car was marked, or whether anyone else was present, leaving the record too vague to support an inference of suspicious motive.28