Illinois v. Wardlow: Case Brief

Instructor: Brittany McKenna

Brittany is a licensed attorney who specializes in criminal law, legal writing, and appellate practice and procedure.

The Supreme Court's decision in Illinois v. Wardlow redefined the concept of 'reasonable suspicion' in police stops. Read this lesson to learn about the facts of the case and the Supreme Court's influential decision.

Stop and Frisk?

Imagine that you're walking down the street, minding your own business, when a police cruiser pulls alongside you. An officer climbs out and begins to ask you some questions. You're confident you haven't broken any laws, but you also want to cooperate with the officer.

Can the officer search you for weapons? Or arrest you on the spot?

In 2000, the United States Supreme Court sought to answer that very question in its Illinois v. Wardlow decision.

Questions Presented to the Supreme Court

The Fourth Amendment of the United States Constitution protects people from unreasonable searches and seizures. The Fourth Amendment has been interpreted to require police officers to take certain steps before they can stop and search a suspect or effect an arrest.

Before a police officer can make an arrest without an arrest warrant, the officer must have a reasonable suspicion that the suspect has broken the law. A reasonable suspicion must be more than a 'hunch'--it must be based on 'specific and articulable' facts.

The question presented to the Supreme Court in Illinois v. Wardlow was: can reasonable suspicion to arrest a suspect be based solely on the fact that the suspect suddenly and without provocation ran from police officers in a high crime area? In other words, does flight alone create reasonable suspicion of criminal activity?

Facts of the Case

Chicago police officers on patrol observed Sam Wardlow standing in front of a house while holding a bag. Wardlow wasn't breaking the law--in fact, he wasn't acting suspiciously at all. Upon spotting the patrol car, Wardlow suddenly began running towards an alley. The officers followed Wardlow in the cruiser, eventually catching up to him and detaining him.

The officers then frisked Wardlow for weapons. They also searched Wardlow's bag, where they found a revolver. Wardlow was arrested and charged with weapons violations.

Before his trial, Wardlow tried to have the evidence regarding the revolver thrown out (or, 'suppressed') on the grounds that the officer's didn't have a reasonable suspicion to conduct their search of him. The Illinois trial court disagreed, and Wardlow was convicted on that evidence.

Wardlow appealed his case all the way to the Supreme Court, where he argued that unprovoked flight from police in a high crime area doesn't justify a stop and search.

The Supreme Court's Holding and Analysis

In a 5-4 decision, the Supreme Court held that the police had reasonable suspicion to justify the investigative stop.

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