What happened
The U.S. Supreme Court summarily reversed a District of Columbia appellate ruling that had thrown out a juvenile delinquency adjudication on Fourth Amendment grounds, holding that an officer had reasonable suspicion to stop a minor who was backing out of a parking spot after two people fled from the vehicle when police arrived.
In a per curiam opinion, the justices said the District of Columbia Court of Appeals departed from the governing reasonable-suspicion framework by failing to assess the full context of the stop. The high court said courts must look at the "totality of the circumstances" rather than reject the facts in isolation.
The case arose after a Metropolitan Police Department officer responded around 2 a.m. to a radio dispatch about a suspicious vehicle at a specific address. When the officer arrived, two people immediately ran from the car, at least one door was left open, and the driver began backing out of the parking space while a rear door remained open.
R.W., who was a minor at the time, moved to suppress evidence obtained after the officer ordered him to put his hands up. The trial court denied suppression, and after a bench trial adjudicated R.W. delinquent on charges including unauthorized use of a motor vehicle, felony receipt of stolen property, unlawful entry of a motor vehicle and driving without a permit.
The D.C. appellate court reversed the suppression ruling and vacated the delinquency adjudication, concluding the officer lacked reasonable suspicion at the time of the seizure. The Supreme Court disagreed, saying the lower court's approach was inconsistent with decisions requiring a combined assessment of the circumstances known to police.
Justice Jackson dissented from the summary reversal. She said the high court may have been right that the lower court should have given some weight to the unprovoked flight, but said that kind of context-specific adjustment did not justify the unusual step of summary reversal.
The ruling sends the case back after reinstating the high court's view that late-night flight from a vehicle, a suspicious-vehicle dispatch and the driver's attempt to leave with a door open could together establish reasonable suspicion for an investigatory stop.