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Determination of reasonable suspicion has to be based on commonsense inferences about human behavior, and officers are justified in suspecting that defendant was involved in criminal activity based on his flight and the fact that he was in a high crime area. In 1989, the Court ruled in United States v. Sokolow that Drug Enforcement Administration agents had reasonable suspicion to stop a passenger at the Honolulu airport because he paid cash for his ticket, he was travelling under a false name, he was coming from Miami (a known source of illicit drugs), he had spent only 48 hours in Miami (although the round trip flight from Honolulu takes 20 hours), he appeared nervous, and he did not check any of his luggage. There could be many innocent explanations: “A pedestrian may break into a run for a variety of reasons…any of which might coincide with the arrival of an officer in the vicinity.“ Some innocent people may nonetheless wish to avoid contact with the police. Law & Inequality. The Illinois Supreme Court ruled along similar lines, arguing that Wardlow’s stop violated the Fourth Amendment. Casebriefs is concerned with your security, please complete the following, The Nature and Scope of Fourteenth Amendment Due Process; The Applicability of the Bill of Rights to the States, The Right to Counsel, Transcripts and Other Aids; Poverty, Equality and the Adversary System, Lineups, Showups and Other Pre-Trial Identification Procedures, Speedy Trial and Other Speedy Disposition, LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam), You can opt out at any time by clicking the unsubscribe link in our newsletter, Pennsylvania Bd. But when Wardlow noticed the police driving through, he broke into a sprint. She cited Wardlow and several other cases in her dissent. The United States Supreme Court accepted the case for review. Reasonable suspicion justifying a Terry stop is met in this situation. Unlock your Study Buddy for the 14 day, no risk, unlimited trial. Service 299, 2000 Daily Journal DAR 389, 1999 Colo. J. C.A.R. He broke down the possible reasons people might run when encountering police officers. May Synopsis of Rule of Law. This case shifts the balance in the direction of police freedom as opposed to individual rights. Infoplease knows the value of having sources you can trust. With this review of Illinois v. Wardlow, get the facts about the case and its consequences today. Here are the facts and trivia that people are buzzing about. For these individuals, running from the authorities is likely instinct rather than a signal that they’ve committed a crime. How the Illinois v. Wardlow Case Affects Policing. But Wardlow, the court said, had done the opposite of going about his business by running away. 183, 13 Fla. L. Weekly Fed. Those familiar with Freddie Gray, the Baltimore man who died in police custody in 2015 after a “rough ride,” argue that Wardlow played a role in his death. Issue. Are officers justified in suspecting that a defendant was involved in criminal activity based on the combination of their presence in an area of frequent narcotics trafficking and the defendant’s unprovoked flight on noticing them? Thank you and the best of luck to you on your LSAT exam. Illinois v. Wardlow is not a Supreme Court case that most Americans know well enough to cite by name, but the ruling has made a serious impact on policing. Justice John Paul Stevens concurred in part and dissented in part in the course of saying he agreed with the court’s rejection of a rule proposed by the state courts authorizing the detention of anyone who flees at the sight of a police car. Of Probation and Parole v. Scott, Board of Education of Independent School District No. Infoplease is part of the FEN Learning family of educational and reference sites for parents, teachers and students. Justice Sonia Sotomayor expressed her dismay at the decision, arguing that the high court has already given the authorities ample opportunity to stop members of the public for little to no reason. "Illinois v. Wardlow and the Crisis of Legitimacy: An Argument for a 'Real Cost' Balancing Test". Terry v. Ohio: Supreme Court Case, Arguments, Impact, 5 Common Misconceptions About Black Lives Matter, Katz v. United States: Supreme Court Case, Arguments, Impact, Tennessee v. Garner: Supreme Court Case, Arguments, Impact, Florida v. Bostick: Supreme Court Case, Arguments, Impact, United States v. Jones: Supreme Court Case, Arguments, Impact, Graham v. Connor: The Case and Its Impact, Chimel v. California: Supreme Court Case, Arguments, Impact, The Fourth Amendment: Text, Origins, and Meaning, Carroll v. U.S.: Supreme Court Case, Arguments, Impact, Arizona v. Hicks: Supreme Court Case, Arguments, Impact, Illinois v. Gates: Supreme Court Case, Arguments, Impact, Mapp v. Ohio: A Milestone Ruling Against Illegally Obtained Evidence, M.A., English and Comparative Literary Studies, Occidental College, B.A., English, Comparative Literature, and American Studies, Occidental College. Also, police stops overwhelmingly took place in majority-minority neighborhoods. CitationIllinois v. Wardlow, 528 U.S. 119, 120 S. Ct. 673, 145 L. Ed. He reviewed a series of often-conflicting factors that the Courts have relied on to justify a police stop: having one-way tickets and having round-trip tickets; taking a nonstop flight and changing planes; having no luggage, having a gym bag, and having new suitcases; acting nervously and acting too calmly. In Illinois, the Court relied on that ruling, as well as on precedents from other cases in which presence in a high crime area and unprovoked flight could be used by the police as factors contributing to “reasonable suspicion.“, Justice John Paul Stevens wrote an opinion concurring in part and dissenting in part. Need a reference? Information Please®, ©2005 Pearson Education, Inc. All Rights Reserved. videos, thousands of real exam questions, and much more. FEN Learning is part of Sandbox Networks, a digital learning company that operates education services and products for the 21st century.

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