The U.S. Supreme Court reversed a District of Columbia Court of Appeals ruling on April 20, holding that a police officer had reasonable suspicion to stop a driver after two people fled from a vehicle as officers arrived. The case, District of Columbia v. R.W., centered on whether Metropolitan Police Officer Clifford Vanterpool violated the Fourth Amendment when he stopped R.W., who was a minor at the time. In a per curiam opinion, the Court said the D.C. Court of Appeals failed to properly consider the “totality of the circumstances” surrounding the stop. The Supreme Court granted the petition for certiorari, reversed the lower court’s judgment and remanded the case for further proceedings.  

Late-Night Dispatch Led to Encounter

According to the opinion, Officer Vanterpool received a radio dispatch in the early morning hours directing him to check on a suspicious vehicle at a specific address in Washington, D.C. He arrived at the apartment building around 2 a.m. in a marked police vehicle. As he entered the parking lot, the officer saw two people immediately run from a car, which the Court described as “unprovoked,” noting that “[p]olice had not done anything other than simply pull up.” The runners left at least one car door open, and the driver, identified as R.W., began backing out of the parking space while the rear door was still open.

Vanterpool then parked behind the car, got out of his vehicle, ordered R.W. to put his hands up and drew his service weapon. The District of Columbia later charged R.W. with unauthorized use of a motor vehicle, felony receipt of stolen property, unlawful entry of a motor vehicle and operating a vehicle in the District of Columbia without a permit. R.W. moved to suppress the evidence obtained after the stop, arguing that the officer lacked reasonable articulable suspicion. The trial court denied the motion and later adjudicated R.W. delinquent on all counts after a bench trial.

Lower Court Had Reversed Delinquency Adjudication

The D.C. Court of Appeals reversed the trial court’s denial of the suppression motion and vacated R.W.’s delinquency adjudication. The appellate court focused on whether the facts known to Officer Vanterpool at the time he ordered R.W. to put his hands up created an objectively reasonable suspicion that criminal activity was occurring. In doing so, the D.C. court excluded, or “excis[ed],” two facts from its analysis: the radio dispatch call and the flight of R.W.’s companions. After setting those facts aside, the court concluded that the remaining facts — the late hour and the car’s movement — were not enough to justify the stop.

The Supreme Court disagreed with that approach. The Court said reasonable suspicion must be evaluated by looking at the “‘totality of the circumstances’” and warned that this standard does not allow courts to reject facts in isolation from one another. Citing prior precedent, the Court said reasonable suspicion allows officers to make “‘commonsense judgments and inferences about human behavior.’” The Court concluded that Officer Vanterpool “clearly had reasonable suspicion to stop R.W.”

Court Points to Flight, Open Door and Attempt to Leave

The Supreme Court said the officer was already on alert because of the late-night dispatch about a suspicious vehicle. It then emphasized that two people fled from the car immediately after seeing police arrive. The Court quoted its prior decision in Illinois v. Wardlow, stating that “unprovoked flight upon noticing the police . . . is certainly suggestive” of wrongdoing. The Court also noted that R.W. was the driver and began backing out of the space after the passengers fled, despite the car door remaining open.

The opinion said the conduct was suspicious when viewed together. “For most drivers, it would be a surprising event for their back-seat passengers to exit the car and run headlong away from them,” the Court wrote. “But we doubt that most would respond by putting their car into reverse and attempting to drive away without at least checking whether the doors were closed.” The Court said R.W.’s actions, combined with the “panicked flight of his companions,” strongly suggested he was engaged in unlawful conduct he wished to hide from police.

Supreme Court Criticizes ‘Divide-and-Conquer’ Review

The Court said the D.C. Court of Appeals reached the wrong result by separating facts that should have been considered together. The opinion stated that the totality-of-the-circumstances test “precludes this sort of divide-and-conquer analysis.” The Court also quoted District of Columbia v. Wesby, saying “the whole is often greater than the sum of its parts—especially when the parts are viewed in isolation.” According to the Court, the lower court’s analysis improperly left out “the most revealing aspect of the encounter.”

The Court acknowledged that innocent explanations might exist for R.W.’s behavior. The lower court had suggested that R.W. “may not even have noticed that his companions left the door open.” But the Supreme Court rejected that as dispositive, stating that reasonable suspicion “need not rule out the possibility of innocent conduct.” Based on the full encounter, the Court said Vanterpool drew a “commonsense inference” that all three people in the car, including the driver, were trying to hide wrongdoing from police.

Jackson Dissents, Sotomayor Would Have Denied Review

Justice Ketanji Brown Jackson dissented, arguing that the D.C. Court of Appeals understood and applied the correct Fourth Amendment standard. She said the lower court properly walked through the relevant factors before weighing them together. “Any readable analysis will, of necessity, tick through factors, finding some weighty, others less so, and still others not at all, before piling them on a scale and assessing the result,” Jackson wrote. She added, “That is what the court below did here, and it was right to do so.”

Jackson said she did not believe the case warranted summary reversal by the Supreme Court. She acknowledged that the D.C. Court of Appeals’ use of the word “excis[ed]” may have been “poor word choice,” but said she did not view it as a true methodological error. In her view, the Supreme Court was largely correcting a fact-specific assessment rather than resolving a major legal conflict. Justice Sonia Sotomayor did not join the dissent but would have denied the petition for a writ of certiorari.

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