Around 2:00 a.m., a District of Columbia police officer responded to a radio call concerning a suspicious vehicle at a specific address. When the officer drove into the parking lot, two passengers immediately fled from the vehicle and left a rear door open. R.W., who was sitting in the driver’s seat, then began backing the vehicle out of its parking space with the door still open. The officer blocked the vehicle, drew his weapon, and ordered R.W. to raise his hands.
Evidence discovered after the stop led to R.W.’s juvenile adjudication for several vehicle-related offenses. The District of Columbia Court of Appeals reversed the denial of R.W.’s suppression motion, concluding that the officer lacked reasonable suspicion to stop him. In reaching that result, the D.C. court gave no weight to the dispatch report or the passengers’ flight and evaluated the remaining circumstances separately.
The Supreme Court summarily reversed and remanded. In a per curiam opinion, the Court held that the officer had reasonable suspicion to stop R.W. The Court reasoned that a Terry stop is lawful when, under the totality of the circumstances, an officer has a particularized and objective basis for suspecting criminal activity. That analysis does not permit courts to isolate individual facts, identify possible innocent explanations for each, and then remove them from consideration.
The Supreme Court reasoned that the late-night suspicious-vehicle report, the passengers’ immediate unprovoked flight, and R.W.’s attempt to back away with the rear door still open collectively supported reasonable suspicion. The possibility of an innocent explanation did not eliminate the reasonable inference of criminal activity. The decision does not alter the reasonable-suspicion standard; it reinforces the requirement that reviewing courts consider the “whole picture” rather than employ a “divide-and-conquer” analysis.
Justice Jackson dissented, arguing that the D.C. Court of Appeals had not actually abandoned the totality-of-the-circumstances test but had simply assigned different weight to the individual facts. She also questioned whether a fact-specific disagreement warranted summary reversal. Justice Sotomayor would have denied certiorari.
Certiorari to the District of Columbia Court of Appeals
Per curiam opinion
Dissenting opinion by Jackson
Justice Sotomayor would have denied certiorari
Click here to read the opinion.