Page 14 - Critical Tasks in Law Enforcement 2020-2021 Sessioin

Task: Seizure Based on Reasonable Suspicion

Illinois v. Wardlow, 528 U.S. 119 (2000).

The unprovoked flight of a citizen upon seeing a police officer, while

in a high crime area, is sufficient to establish reasonable suspicion
to make an investigatory stop.

• Officer must be able to articulate factors, beyond mere flight, in

order to justify stop.

• In this case, Court found articulation of “high crime” area sufficient

when coupled with other factors.

• In a footnote, the Court asserted that it was not deciding whether a

frisk would be justified under these circumstances.

©2021 Jack Ryan Legal & Liability Risk Management Institute 13