Illinois v. Wardlow case brief

Illinois v. Wardlow case brief summary
528 U.S. 119 (2000)

CASE SYNOPSIS

The State appealed the judgment of the Supreme Court of Illinois, which upheld the grant of defendant's motion to suppress evidence, concluding that sudden flight in a high crime area did not create a reasonable suspicion justifying a Terry stop.

CASE FACTS
Defendant fled upon seeing police officers patrolling an area known for heavy narcotics trafficking. Two of the officers caught up with him, and conducted a protective pat-down search for weapons. Defendant was arrested when officers discovered a .38-caliber handgun. The trial court denied defendant's motion to suppress, but the appellate court reversed. The state supreme court agreed, concluding that sudden flight in a high crime area did not create a reasonable suspicion justifying a Terry stop.

DISCUSSION

• The United States Supreme Court granted certiorari and reversed. 
• The Court found that nervous, evasive behavior was a pertinent factor in determining reasonable suspicion for a Terry stop, and that headlong flight was the consummate act of evasion. 
• The Court found that the determination of reasonable suspicion had to be based on commonsense judgments and inferences about human behavior, and that officers were justified in suspecting that defendant was involved in criminal activity based on his presence in an area of heavy narcotics trafficking and his unprovoked flight upon noticing the police.

CONCLUSION
The judgment was reversed and remanded; defendant's presence in an area of heavy narcotics trafficking and his unprovoked flight upon noticing police created a reasonable suspicion justifying a Terry stop.



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