SCOTUS issues per curiam opinion concluding officer had reasonable suspicion for seizure
D.C. v. R.W., USSC No. 25-248, 2/25/2025, reversing In re R.W., 334 A.3d 593 (D.C. 2025); Scotusblog page (with links to briefs)
SCOTUS reverses DC Court of Appeals decision that an officer stopped R.W. without reasonable suspicion and in violation of the Fourth Amendment based on the totality of the circumstances.
An officer in Washington, D.C., received a dispatch call to check out a suspicious vehicle at an address, which was to an apartment building, and arrived there at around 2 a.m. As he turned into the parking lot, two people fled from the car, leaving at least one of the car doors open. The driver then began to back out of a parking space with a rear door still open. The officer parked directly behind the car, left his own vehicle, ordered the driver, R.W., to put his hands up, and drew his gun. On appeal, R.W. raised one argument—that the officer lacked reasonable articulable suspicion sufficient to justify the seizure. (Slip op. at 1).
On appeal, the D.C. Court of Appeals reversed the denial of the motion to suppress and vacated R.W.’s delinquency adjudication. It determined that the trial court had erred by considering two facts in the totality of the circumstances—the dispatch call and the flight of the two passengers. (Slip op. at 2-3). SCOTUS disagrees and holds that these facts are relevant considerations within the test. Whether the officer had reasonable suspicion includes all of the facts available to the officer before he ordered R.W. to put his hands up. (Slip op. at 3). By considering only two of the factors present at the time, the court of appeals employed a “divide-and-conquer analysis” which is precluded under the totality of the circumstances test. (Slip op. at 4-5). The Court notes that “this case reveals the perils of reviewing facts piecemeal and without context.” (Slip op. at 5). SCOTUS concludes by noting that officers need not rule out the possibility of innocent explanations, and reiterating that the reasonable suspicion test requires courts to consider the whole picture. (Slip op. at 5-6).
Justice Sotomayor would deny the petition for writ of certiorari.
Justice Jackson dissents, endorsing the reasoning of the DC Court of Appeals. Justice Jackson believes the lower court properly applied the test, so she is “not sure why our Court sees fit to intervene in this case, let alone to do so summarily.” (Dissent at 1). The justice goes on to consider two reasons why the Court possibly saw it fit to intervene and rejects each in turn, concluding: “Even if I would have assigned more heft to a particular fact in my own first-instance assessment, I would not wordsmith a lower court in this fashion. In my view, this is not a worthy accomplishment for the unusual step of summary reversal.” (Dissent at 2-3).