Illinois v. Wardlow Case Brief

Facts of the case

Sam Wardlow, who was holding an opaque bag, inexplicably fled an area of Chicago known for heavy narcotics trafficking after noticing police officers in the area. When officers caught up with him on the street, one stopped him and conducted a protective pat-down search for weapons because in his experience there were usually weapons in the vicinity of narcotics transactions. The officers arrested Wardlow after discovering that he was carrying handgun. In a trial motion to suppress the gun, Wardlow claimed that in order to stop an individual, short of actually arresting the person, police first had to point to specific reasonable inferenceswhy the stop was necessary. The Illinois trial court denied the motion, finding that the gun was recovered during a lawful stop and frisk. Wardlow was convicted of unlawful use of a weapon by a felon. In reversing, the Illinois Appellate Court found that the officer did not have reasonable suspicion to make the stop. The Illinois Supreme Court affirmed, determining that sudden flight in a high crime area does not create a reasonable suspicion justifying a stop because flight may simply be an exercise of the right to go on one’s way.

Why is the case important?

Defendant William Wardlow was stopped and frisked after looking towards police officers and then running in an area known for heavy narcotics trafficking.

Question

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?

ANSWER

Yes. Reverse and remand the judgment.
Reasonable suspicion justifying a Terry stop is met in this situation. 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.

CONCLUSION

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 common sense 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. The Court concluded that 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.

  • Advocates: James B. Koch Argued the cause for the respondent Malcolm L. Stewart Argued the cause for the United States, as amicus curiae, by special leave of court Richard A. Devine Argued the cause for the petitioner
  • Petitioner: Illinois
  • Respondent: Wardlow
  • DECIDED BY:Rehnquist Court
  • Location: 4035 West Van Buren St
Citation: 528 US 119 (2000)
Argued: Nov 2, 1999
Decided: Jan 12, 2000
Illinois v. Wardlow Case Brief