On Point blog, page 4 of 4
Frisk of Automobile – Minor Traffic Violation — Reasonable Suspicion, Multiple Factors: Furtive Movements, High-Crime Area, et. al
State v. Clemente Lamont Alexander, 2008 WI App 9
For Alexander: Michael C. Demo
Issue: Whether the police had reasonable suspicion to search the glove compartment of a car, stopped for a minor traffic violation (right turn on red without stopping), based on multiple factors: delay in pulling over, furtive movements, high-crime area, and post-stop observation of items on the driver seat normally found in the glove compartment.
Reasonable Suspicion – Stop – Basis – Warrant Execution – leaving house where warrant being executed
State v. Louis Taylor, 226 Wis.2d 490, 595 N.W.2d 56 (Ct. App. 1999)
For Taylor: Donald T. Lang, SPD, Madison Appellate.
Holding: Taylor walked out the back door as police were knocking on the front door to execute a warrant for someone else, in an area described as “high drug … high gang.” The police were entitled to seize him:
We agree with the trial court that the totality of the facts supports a reasonable basis for Veselik’s suspicion that something unlawful was afoot with Taylor.
Reasonable Suspicion – Stop – Basis – High-Crime Area
State v. Tartorius Allen, 226 Wis.2d 66, 593 N.W.2d 504 (Ct. App. 1999)
For Allen: Steven D. Phillips, SPD, Madison Appellate.
Holding:
Allen and his companion being in a high-crime area, standing alone, would not be enough to create reasonable suspicion. A brief contact with a car, standing alone, would not be enough to create reasonable suspicion. Hanging around a neighborhood for five to ten minutes,
Reasonable Suspicion – Frisk – High-Crime Area, et al.
State v. Michael T. Morgan, 197 Wis. 2d 200, 539 N.W.2d 887 (1995)
For Morgan: Wm. J. Tyroler, SPD, Milwaukee Appellate; Calvin Malone
Issue/Holding:
… The court of appeals then held that the search of Morgan was supported by articulable facts in the record, including the “fairly-high-crime-rate area”; Morgan’s driving in two alleys at approximately 4:00 a.m.; Morgan’s nervous and unsuccessful efforts to produce a driver’s license upon request;