Supreme Court Decision Syllabus (SCOTUS Podcast)

DISTRICT OF COLUMBIA v. R.W. (PROBABLE CAUSE TO STOP/TERRY STOP/VEHICLE)

Attorney RJ Dieken, Loki Esq Law, Montana

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0:00 | 16:25

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Totality of the Circumstances is required in considering Probable Cause for a temporary stop. Probable Cause being defined as: "Articulable reasonable suspicion for the officers belief that 'criminal activity is afoot.'"

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Hello, this is RJ Deakin, reading the Supreme Court of the United States opinion in District of Columbia versus RW. I'm petitioned for Red of Search URI to the District of Columbia Circuit Court of Appeals. And this one was decided April 20th, 2026. And again, it's the opinion because it's a percurium opinion in the what we call a grant vacate in remand. In the wee hours of a winter morning in Washington, D.C., District of Columbia, Metropolitan Police Officer Clifford Vanderpool received a radio dispatch call directing him to check out a suspicious vehicle at a specific address. Officer Vanderpool reached the apartment building at that address around 2 a.m. As he turned his marked police vehicle into the parking lot, he saw two people immediately flee from a car, unprovoked, quote unquote, after, quote, police had not done anything other than simply pull up, end quote. The runners left open at least one of the car doors. The driver then began to back out of the parking space, rear door still open. Officer Vanderpool decided to investigate. He parked directly behind the car, left his own vehicle, ordered the driver, RW, to put his hands up, and drew his service weapon. RW raised a single argument on appeal, that Officer Vanderpool lacked reasonable, articulable suspicion sufficient to justify the seizure. The District of Columbia Court of Appeals held that Officer Vanderpool, by stopping RW without reasonable suspicion, violated the Fourth Amendment. We disagree. When an officer makes a brief investigatory stop of persons or vehicles that fall short of a traditional arrest, the Fourth Amendment is satisfied if the officer's actions are supported by reasonable suspicion to believe that criminal activity may be afoot. There's a lot of internal quotations in that one. United States versus Arvisio from 2020, quoting United States versus Socolo from 1989. In asserting whether an officer had reasonable suspicion, a reviewing court must look at the totality of the circumstances of each case. An analysis that precludes the evaluation and rejection of factors in isolation from each other. That's our visa. Because the DC Court of Appeals departed from these principles, and because Officer Vanderpool clearly had reasonable suspicion to stop RW, we reverse. Before trial, RW moved to suppress the evidence obtained after he was stopped. Following a suppression hearing, the trial court denied RW's motion, relying on four factors to conclude that the officer had reasonable suspicion to stop RW. One, the officer had received a radio dispatch call regarding a suspicious vehicle at a specified address. Two, the officer saw two persons fleeing from the vehicle upon his arrival. Three, it was almost 2 a.m. And four, as the officer approached the car, it began backing out of the parking space while the rear driver's side door was still open. After a bench trial, the trial court adjudicated RW delinquent on all counts and assigned RW to one year of probation with conditions. On appeal, the DC Court of Appeals reversed the denial of the motion to suppress and vacated the delinquency adjudication. There's an asterisk there that reads The District of Columbia conceded that Officer Vanderpool seized RW when he first asked RW to put his hands up. So the DC Court of Appeals decided only whether the facts known by the officer Vanterpool created an objectively reasonable suspicion that criminal activity was afoot. And that's uh got an internal sight to Terry versus Ohio from 1968. So uh DC Court of Appeals reversed the denial of the motion to suppress and vacated the delinquency, adjudication, we had the asterisk there, asterisk there, uh, and the court first addressed the legitimacy and weight of each of the factors bearing on reasonable suspicion before weighing that information all together. Um the first step of this analysis, it held that the trial court had erred by considering two factors, the radio dispatch call and the flight of RW's companions. It excised those factors from the analysis, and then concluded that without more, the remaining facts, the late hour and the car's movement, did not give rise to reasonable suspicion. After the DC Court of Appeals ruled, the District of Columbia sought Sergi. The question is whether the facts available to Officer Vanterpool before he ordered RW to put his hands up warranted the stop. In other words, we ask whether Officer Vanterpool had a reasonable suspicion that RW was engaged in criminal wrongdoing. Socalau. Such reasonable suspicion arises when, based on the totality of the circumstances, the detaining officer had a particularized and objective basis for suspecting criminal wrongdoing. Aravizu. And I keep saying Aravizu, but it's A-R-V-I-Z-U, is the spelling there. Um, because I'm probably mispronouncing it. Uh reasonable suspicion depends on the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act. That's Kansas versus Glover from 2020, which was quoting Praeto Navarretti versus California from 2014. It permits officers to make common sense judgments and inferences about human behavior. That's from Glover quoting Illinois versus Wardlow. On the facts of this case, Officer Vantrapo clearly had reasonable suspicion to stop. RW. Already on alert from the late night dispatch call about a suspicious vehicle, the officer observed every person in RW's car respond strangely to an approaching police car. Two people took off running. We have observed that unprovoked flight upon noticing police is certainly suggestive of wrongdoing. Um the driver RW did not run from the car, but his companion's fight flight cast his presence in a suspicious light. After all, we have observed that a car passenger will often be engaged in a common enterprise with the driver and have the same interest in concealing the fruits or the evidence of their wrongdoing. That's Marilyn v. Pringle from 2003, quoting Wyoming versus Houghton from 1999. We need not determine whether that connection alone supported reasonable suspicion because RW was in the car driver's seat and after the passengers fled from the car, began backing out of the parking space, ignoring the car's open back door. For most drivers, it would be a surprising event for their backseat passengers to exit the car and run headlong away from them. 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. RW's own actions, combined with the panicked flight of his companions, strongly suggested that he was like them, engaged in unlawful conduct. He wished to hide from the police. See Sibrin versus New York from 1968, recognizing that deliberately furtive actions and flight at the approach of law enforcement officers are strong indicia of mens rea. Here's section three. The BC Court of Appeals reached a different conclusion by excising the radio dispatch and the conduct of RW's companions from the analysis, and considering only the lateness of the hour and the slight movement of the car. The totality of the circumstances test, however, precludes this sort of divide and conquer analysis. Our precedents have recognized the whole is often greater than the sum of its parts, especially when the parts are viewed in isolation. That's District of Columbia vs. Wespee. Indeed, this case reveals the perils of reviewing facts piecemeal and without context. Take the passenger's flight from the car. We have little doubt that in some circumstances, an officer could not reasonably attribute his suspicion of a fleeing individual to bystanders milling nearby. Um CF uh Yabara versus Illinois, recognizing that a person's mere propincuity to others, independently suspected of criminal activity, does not, without more, give rise to probable cause to search that person. But the whole picture here tells a different story. Cortez is the site there at 417. After watching two people flee from a suspicious car, a reasonable officer would surely question the driver's next move. Why would the driver hurriedly back up the car without even closing the car door left open by his fleeing companions? Perhaps one could imagine an innocent explanation for such unusual behavior. The court below, for example, surmised that RBW may not even have noticed that his companions left the open door, but we have consistently recognized that reasonable suspicion need not rule out the possibility of innocent conduct. That's Navarette 572 at 403. Quoting Aravizu at 277. Based on everything, the officer observed in the night in question, he drew the common sense inference that all three people in the car, including the driver, were trying to hide wrongdoing from the police. That's um Glover is the site there. The Fourth Amendment requires that a court slosh its way through a fact-bound morass. That's Barnes versus Felix from 2025 vote quoting Scott versus Harris from 2007. There may be no easy to apply legal test or on-off switch in this context. That's Barnes quoting against Scott. But one thing is clear. Uh that's Wesby quoting Cortez. The DC Court of Appeals expressly declined to do that. It instead considered only the observations that one, it was 2 AM, and two, RW reversed a few feet in a parking spot while the vehicle's rear door was open. ID citation there, uh expressly excised from its analysis was, for example, the compelling fact that two individuals fled the vehicle as soon as they spotted the police car. Pretending that the most revealing aspect of the encounter did not happen is incompatible with the totality of the circumstances approach. Um and they've put M-dashes in the middle of the totality of the circumstances required by our precedence. The petition for Sir Surari and RW's motion to proceed in forma paparis are granted. The judgment of the District of Columbia Court of Appeals is reversed, and the case is remanded for further proceedings not inconsistent with this opinion. It is so ordered. And Justice Sotomayer would deny the petition for a writ of Sir Surari. Um that is the end of the recording. Thanks for tuning in, folks. Um I was laughing thinking about um how many times I have um closed a rear car door by just goosing the gas a little bit, um, which would be consistent with backing up, but there were other circumstances. Anyway, if you folks um would like to, there's like a robot podcast or an AI slot podcast that is now impersonating us, I guess. It's using the old photograph um that my friend Davio Kelly um had taken that I used to use for this podcast, which is funny in of itself. Um, and then it is posting the AI readings, like robot voice readings, um, which I guess are probably more accurate than mine, but I mean, you want to listen to a human, I'd hope. Um, so they're posting the those readings, um uh uh but only selected ones, which is the part that exceptionally worries me. So if y'all you know happen to be on your podcast source or something, report the um report that podcast. And I I was using um impersonating somebody else, which I guess I'm doing too, or you know, make something up. Half you people are lawyers. Uh, I'm sure you can find something to report in whatever your um things are. And the hope is that maybe we can get back to just uh um just the human readings and posting all of them. Have a good rest of your night, folks.