District of Columbia v. R.W., 608 U.S. ___ (2026)
TOPIC: Fourth Amendment / Investigatory Stop / Reasonable Suspicion.
In District of Columbia v. R.W., 608 U.S. ___ (2026), the Supreme Court of the United States affirmed that when courts are tasked with assessing whether a police officer had reasonable suspicion, the court must consider the totality of the circumstances, which precludes evaluating and rejecting individual factors in isolation from each other. In this case, the Court considered whether an officer responding to a late-night report of a suspicious vehicle had reasonable suspicion to stop its driver after two passengers fled as police approached and the driver began backing out while the rear door was ajar. Viewed together through the lens of the totality of the circumstances, the Supreme Court held that the officer clearly had reasonable suspicion to justify the investigatory stop.
Summary of the Facts
On an early winter morning, D.C. Metropolitan Police Officer C. Vanterpool was dispatched to investigate a suspicious vehicle at a nearby address. The officer reached the apartment building at approximately 2:00 a.m. and entered the parking lot driving his marked police vehicle. As soon as he entered the lot, he noticed two people who immediately fled from a vehicle unprovoked upon seeing the marked cruiser pull up. One of the individuals who ran from the car left one of the rear doors of the vehicle open. Despite this, the driver of the vehicle began backing out of the parking space with the door still open. Officer Vanterpool parked directly behind the car and exited his vehicle. He then issued commands for the driver, a minor named R.W., to put his hands up and drew his service weapon.
In the aftermath, R.W. was charged with unauthorized use of a motor vehicle, felony receipt of stolen property, unlawful entry of a motor vehicle, and operating a vehicle in the District of Columbia without a permit. At trial, R.W. filed a motion to suppress the evidence recovered during his arrest. In response, the government argued that intervention was warranted based on the time of night, the dispatch call that reported a suspicious vehicle, unprompted flight by the passengers, and the driver’s attempt to leave the lot. The lower court agreed with the officers and denied R.W.’s motion to suppress.
On appeal, the United States Court of Appeals for the District of Columbia found that officers did not have reasonable suspicion to justify police intervention and thus held that Officer Vanterpool’s stop of R.W. without reasonable suspicion violated the Fourth Amendment. As such, the lower court’s ruling was vacated, and the denial of the motion to suppress was reversed. The District of Columbia appealed, seeking review by the Supreme Court of the United States.
The Supreme Court granted certiorari to decide “whether Officer Vanterpool had a reasonable suspicion that R.W. was engaged in criminal wrongdoing.” United States v. Sokolow, 490 U.S. 1, 7 (1989).
Supreme Court of the United States
The Court considered “whether the facts available to Officer Vanterpool, before he ordered R.W. to put his hands up, warranted the stop.” The high Court held that Officer Vanterpool clearly had reasonable suspicion to stop R.W. and found that the D.C. Court of Appeals departed from the standard principles that guide this Fourth Amendment inquiry. As such, the Supreme Court ultimately reversed the D.C. Court of Appeals’ judgment.
The Court began its analysis by reiterating that such reasonable suspicion arises when, based on the “‘totality of the circumstances,’” the detaining officer had a “‘particularized and objective basis’” for suspecting criminal wrongdoing. Arvizu, 534 U.S. at 273. Moreover, reasonable suspicion “‘depends on the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act,’” and permits officers to make “‘commonsense judgments and inferences about human behavior.’” Kansas v. Glover, 589 U.S. 376, 380 (2020).
Applying that framework to the totality of the circumstances presented in this case, the Court found that Officer Vanterpool clearly had reasonable suspicion to stop R.W. Considering the facts in this case, Officer Vanterpool was already on alert from the late-night dispatch call concerning a suspicious vehicle when he observed two passengers respond strangely by fleeing from the vehicle as his police car approached. The Court maintained that it has previously recognized that “unprovoked flight upon noticing the police . . . is certainly suggestive” of wrongdoing.
Here, although the driver of the vehicle, R.W., did not run from the car, the Court explained that his companions’ flight nevertheless cast his presence in a suspicious light. Citing prior precedent, the Court reiterated that “‘a car passenger . . . will often be engaged in a common enterprise with the driver and have the same interest in concealing the fruits or the evidence of their wrongdoing.’” Maryland v. Pringle, 540 U.S. 366, 373 (2003) (quoting Wyoming v. Houghton, 526 U.S. 295, 304–305 (1999)).
The Court declined to decide whether the connection between the driver’s actions and the actions of the two passengers established reasonable suspicion because R.W. was in the driver’s seat and his own conduct supported such a finding. After the passengers fled from the vehicle, R.W. began backing out of the parking space and blatantly ignored that the back door of the vehicle was open. The Court reasoned that most drivers would be surprised by their passengers’ sudden flight and most likely would not respond by attempting to drive away without first checking whether the doors were closed. As such, the Court found that R.W.’s own actions, combined with the panicked flight of his companions, strongly suggested that he was, like them, engaged in unlawful conduct he wished to hide from police. Sibron v. New York, 392 U.S. 40, 66 (1968).
The Court then considered the conclusion reached by the D.C. Court of Appeals, which found that Officer Vanterpool did not have reasonable suspicion considering the facts. To reach this result, the Court of Appeals “first assessed the legitimacy and weight of each of the factors bearing on reasonable suspicion” before “weighing that information all together.” While assessing each factor, the Court of Appeals determined that the trial court should not have considered the dispatch call regarding the suspicious vehicle or the flight by the two passengers. After removing those factors from its purview, the Appellate Court concluded that the driver’s attempt to leave the lot and time of night were insufficient to create reasonable suspicion.
However, on certiorari, the Supreme Court disagreed and held that the Court of Appeals erred in evaluating and rejecting factors in isolation from each other. The Court further emphasized that the totality of the circumstances must be considered in evaluating whether an officer had reasonable suspicion. An officer may make a “brief investigatory stop of persons or vehicles that falls short of a traditional arrest…if the officer’s action is supported by reasonable suspicion to believe that criminal activity ‘may be afoot.’” United States v. Arvizu, 534 U.S. 266, 273 (2002) (quoting United States v. Sokolow, 490 U.S. 1, 7 (1989)).
The Court explained that when a reviewing court is tasked with assessing whether an officer had reasonable suspicion, the court must “look at the ‘totality of the circumstances’ of each case.” The Court emphasized that the totality of the circumstances test precludes the “evaluation and rejection” of “factors in isolation from each other.” Arvizu, 534 U.S. at 273–274. Relying on established precedents, the Court recognized that “the whole is often greater than the sum of its parts, especially when the parts are viewed in isolation.” District of Columbia v. Wesby, 583 U.S. 48, 60–61 (2018).
The Court emphasized that an officer could not reasonably assume nearby bystanders were involved simply because someone else ran away in some cases. However, a reasonable officer in Officer Vanterpool’s place would likely question what the driver would do next. The Court recognized that R.W. could simply not have noticed the door was open when leaving, emphasizing that reasonable suspicion need not eliminate every innocent explanation and only needs to make criminal activity reasonably suspect under the circumstances. However, the Court found that under the totality of the circumstances, Officer Vanterpool drew the inference that R.W. and the passengers were trying to hide wrongdoing from him.
The Supreme Court explained that the “totality of the circumstances” requires courts to consider “the whole picture,” and the Fourth Amendment requires that a court “slosh its way through” a “fact-bound morass.” Barnes v. Felix, 605 U.S. 73, 80 (2025). In this case, the D.C. Court of Appeals failed to look at the totality of the circumstances by isolating each factor from each other in evaluating whether Officer Vanterpool had reasonable suspicion to stop R.W. Instead of applying the totality of the circumstances, the Court of Appeals considered only the observations that (1) it was 2:00 a.m. and (2) R.W. reversed a few feet in a parking spot while the vehicle’s rear door was open.
Expressly removed from its analysis was the compelling fact that two individuals fled the vehicle as soon as they spotted the police car. The Court noted that “pretending that the most revealing aspect of the encounter did not happen is incompatible with the totality-of-the-circumstances approach required by our precedents.”
Ultimately, the Supreme Court found that based on the totality of the circumstances, the dispatch call, time of night, unprompted flight of the passengers, and R.W.’s attempt to leave supported a finding of reasonable suspicion, allowing Officer Vanterpool to make a brief investigatory stop. Therefore, the Court reversed the judgment of the District of Columbia Court of Appeals and remanded the case for further proceedings consistent with its ruling.