The justices said a D.C. appeals court improperly parsed the facts of an early-morning car stop rather than considering the full circumstances supporting reasonable suspicion.
What happened
The U.S. Supreme Court summarily reversed a D.C. Court of Appeals decision that had suppressed evidence in a juvenile unauthorized-use case, holding that police had reasonable suspicion to stop the driver of a car after two passengers fled from it in the early morning.
In a per curiam decision issued April 20, the justices granted certiorari, reversed and remanded in District of Columbia v. R.W., restoring the trial court's refusal to suppress evidence obtained after Officer Clifford Vanterpool stopped R.W. in an apartment-building parking lot. The court said the officer "clearly had reasonable suspicion to stop R. W."
The ruling reinforces that reasonable suspicion must be assessed by the totality of the circumstances, not by rejecting individual facts in isolation. The court faulted the D.C. Court of Appeals for setting aside the suspicious-vehicle dispatch and the flight of R.W.'s companions, then concluding that the remaining facts did not justify the stop.
The case arose after Vanterpool responded around 2 a.m. to a suspicious-vehicle dispatch, saw two people flee from a car, and then saw the driver begin backing out while at least one rear door remained open. The District charged R.W., who was a minor at the time, with several vehicle-related offenses, and the trial court denied his suppression motion before adjudicating him delinquent and imposing one year of probation.
The D.C. Court of Appeals reversed the suppression ruling and vacated the delinquency adjudication after excluding the dispatch call and the passengers' flight from its reasonable-suspicion analysis. The Supreme Court said that approach was incompatible with Fourth Amendment precedent requiring courts to look at the whole picture.
The per curiam opinion said the driver's actions, combined with the passengers' flight, strongly suggested that he was engaged in unlawful conduct he wanted to hide from police. Justice Jackson dissented, saying the case was not worthy of summary reversal, while Justice Sotomayor would have denied certiorari.