Illinois v. Wardlow
Facts
Chicago police officers in a four-car caravan were converging on an area known for heavy narcotics trafficking to investigate drug transactions. Officer Nolan saw Wardlow standing next to a building holding an opaque bag; Wardlow looked in the officers' direction and fled. Two officers pursued, cornered, and stopped him, and Nolan immediately conducted a protective patdown search for weapons based on his experience that weapons were common near narcotics transactions. When Nolan felt a heavy, hard object in the bag shaped like a gun, he opened it, found a loaded .38-caliber handgun, and Wardlow was arrested.
Issue
Whether police officers had reasonable suspicion under the Fourth Amendment to make a Terry stop when Wardlow engaged in unprovoked flight after noticing police officers in an area known for heavy narcotics trafficking.
Rule
An officer may conduct a brief investigatory stop when the officer has a reasonable, articulable suspicion that criminal activity is afoot. Presence in an area of expected criminal activity, standing alone, is not enough, but a location's characteristics are relevant contextual considerations, and unprovoked headlong flight is a pertinent form of nervous, evasive behavior that can contribute to reasonable suspicion under the totality of the circumstances.
See the holding & full analysis
Create a free KwikCourt account to unlock the rest of this brief — and practice the case.
- The court's holding and reasoning
- Doctrine tests, pitfalls & exam hypotheticals
- 10 practice questions + 4 AI-graded essays on this case
Test yourself
Was the stop most likely lawful under the Fourth Amendment?