District of Columbia v. R.W.
No. 25-248 · Decided April 20, 2026
Whether the facts available to Officer Vanterpool before he ordered R.W. to put his hands up warranted the stop. The Court held that the totality of the circumstances, including a suspicious vehicle dispatch, the unprovoked flight of passengers, and the driver's furtive movement, provided the reasonable suspicion necessary to justify a brief investigatory stop under the Fourth Amendment.
Vote & lineupPer Curiam
The question
Whether the facts available to Officer Vanterpool before he ordered R.W. to put his hands up warranted the stop. Specifically, the Court asks whether the officer had a reasonable suspicion that R.W. was engaged in criminal wrongdoing. This involves determining if the "totality of the circumstances" provided an objective basis for the seizure under the Fourth Amendment.
Petitioner's argument
- The officer had reasonable suspicion to stop R.W. based on the totality of the circumstances, including the radio dispatch and the flight of the passengers.
- The D.C. Court of Appeals erred by employing a "divide-and-conquer analysis" that "excised" key facts from the record.
- The combination of the late hour, the fleeing companions, and the driver's attempt to leave with an open door strongly suggested criminal activity.
- Reasonable suspicion does not require an officer to rule out every possible innocent explanation for the observed behavior.
Respondent's argument
- Officer Vanterpool lacked reasonable articulable suspicion sufficient to justify the seizure.
- The remaining facts—the late hour and the slight movement of the car—were insufficient on their own to justify a stop.
- The radio dispatch call and the flight of the companions should be excluded from the analysis.
- The driver's actions, such as backing out of a parking space, were not inherently suspicious and may have been innocent.
The decision
- The Court held that Officer Vanterpool had reasonable suspicion to stop R.W. under the Fourth Amendment.
- The Court applied the "totality of the circumstances" test, which requires a "particularized and objective basis" for suspecting criminal wrongdoing, citing *United States v. Arvizu* and *United States v. Cortez*.
- The Court emphasized that reasonable suspicion depends on "factual and practical considerations of everyday life" and "commonsense judgments," invoking *Kansas v. Glover*, *Prado Navarette v. California*, and *Illinois v. Wardlow*.
- The Court found that "unprovoked flight upon noticing the police" is "certainly suggestive" of wrongdoing under *Illinois v. Wardlow*.
- The Court noted that passengers are often engaged in a "common enterprise" with the driver, citing *Maryland v. Pringle* and *Wyoming v. Houghton*.
- The Court reasoned that R.W.'s attempt to drive away while the rear door remained open, combined with the flight of his companions, constituted "deliberately furtive actions" indicative of "mens rea" under *Sibron v. New York*.
- The Court clarified that reasonable suspicion "need not rule out the possibility of innocent conduct," citing *Prado Navarette v. California* and *United States v. Arvizu*.
- The Court concluded that the D.C. Court of Appeals committed a legal error by "excising" factors from the analysis, a "divide-and-conquer analysis" precluded by *United States v. Arvizu* and *District of Columbia v. Wesby*.
Separate opinions
SOTOMAYOR, concurring, joined by nobody
- Justice Sotomayor stated she would deny the petition for a writ of certiorari.
JACKSON, dissenting, joined by nobody
- Argues that the D.C. Court of Appeals' factor-by-factor analysis is a standard part of judicial reasoning and that the use of the word "excised" was a matter of poor word choice rather than methodological error.
- Contends that the radio dispatch call may be an "unsupported hunch of a fellow officer," citing *Whiteley v. Warden* and *United States v. Hensley*.
- Argues that the case is too "factbound" to justify the "unusual step of summary reversal."