What happened
The U.S. Supreme Court on Monday reversed a District of Columbia Court of Appeals ruling that had found a police stop of R.W. unsupported by reasonable suspicion, faulting the local appellate court for stripping key facts out of the Fourth Amendment analysis.
In a per curiam opinion, the high court said Officer Clifford Vanterpool had reasonable suspicion to stop R.W. under the totality of the circumstances after responding to a suspicious-vehicle dispatch, seeing two people flee from the car and then watching R.W. begin backing out with a rear door still open.
The court said Fourth Amendment reasonable suspicion does not require judges to rule out innocent explanations. Rather, the opinion said, courts must assess the whole encounter and may credit commonsense inferences about human behavior.
The case arose from a roughly 2 a.m. police response in Washington, D.C. The trial court denied R.W.'s suppression motion, later adjudicated him delinquent on all counts and assigned one year of probation with conditions. The D.C. Court of Appeals reversed the suppression ruling and vacated the delinquency adjudication.
The Supreme Court said that approach was wrong because the totality-of-the-circumstances test “precludes this sort of divide-and-conquer analysis.” The opinion emphasized that the passengers' flight, the late hour, the dispatch and R.W.'s own movement of the car had to be considered together rather than pared down to only the time of night and slight movement of the vehicle.
The court granted certiorari, reversed the D.C. Court of Appeals and remanded for further proceedings. Justice Sotomayor would have denied certiorari, while Justice Jackson dissented, saying the local court had applied the correct inquiry and that the case did not warrant summary reversal.