Experimental. Doctrines is a new Annlex feature, starting with four areas: Self-incrimination, Brady, Terry and Miranda. Each page collects what courts have said about a leading case, quoted from the opinions that cite it. Annlex Chat uses these collections to help find relevant cases; what a case holds still comes from its opinion. We'd like to hear what's useful, missing or wrong: Send feedback
Unprovoked Flight in a High-Crime Area as Reasonable Suspicion
Leading case
Illinois v. Wardlow, 528 U.S. 119 (2000)
How courts have described it
concluding that a suspect's flight upon seeing police officers while in a high-crime area justified a Terry stop
United States v. Alvin Houston, 920 F.3d 1168 (8th Cir. 2019)
holding that an individual’s “unprovoked” flight was sufficient to give officers reasonable suspicion to conduct a Terry stop
United States v. Rodella, 804 F.3d 1317 (10th Cir. 2015)
holding that officer’s stop was reasonable where the individual in question was in a high crime area, demonstrated nervous and evasive behavior, and attempted to run away upon seeing the police
Holeman v. City of New London, 425 F.3d 184 (2d Cir. 2005)
holding that the defendant’s unprovoked flight from police officers in a high crime area created reasonable suspicion for a Terry stop
United States v. Hauk, 412 F.3d 1179 (10th Cir. 2005)
holding that, in a high crime area, unprovoked, headlong flight from police can form the basis for reasonable suspicion under Terry
United States v. Angel Vargas, 369 F.3d 98 (2d Cir. 2004)
holding that flight from police officers in an area known for drug activity is enough to create reasonable suspicion
United States v. Carl Eugene Stephens, Opinion, 206 F.3d 914 (9th Cir. 2000)
holding that an individual’s unprovoked flight upon noticing the police, in conjunction with his presence in a high crime area, may constitute reasonable suspicion
Marcano v. City of Schenectady, 38 F. Supp. 3d 238 (N.D.N.Y. 2014)
holding that a police officer had reasonable articulable suspicion to stop a defendant where defendant, without provocation, fled upon seeing police officers
State v. Mitchell, 592 S.E.2d 543 (N.C. 2004)
concluding that the officer had reasonable, articulable suspicion to stop an individual in a high crime area who ran upon seeing officers approach
State v. Cunningham, 2014 Ohio 1924 (Ohio Ct. App. 2014)
holding that unprovoked, headlong flight from the police can support a finding of reasonable suspicion
Burkes v. State, 842 N.E.2d 426 (Ind. Ct. App. 2006)
Related doctrines
About this page
The quotations above are from court opinions that cite the leading case, in each court's own words. The heading is a short label Annlex generated from those quotations. It has not been reviewed by a lawyer and is not legal advice.