Citation. United States v. Arvizu, 534 U.S. 266, 122 S. Ct. 744, 151 L. Ed. 2d 740, 70 U.S.L.W. 4076, 2002 Cal. Daily Op. Service 380, 2002 Daily Journal DAR 499, 15 Fla. L. Weekly Fed. S 81 (U.S. Jan. 15, 2002)
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Brief Fact Summary.
After tripping magnetic sensors on a common smuggling route with his mini-van, respondent was observed and eventually stopped by a border agent. A search of the van revealed 100 pounds of marijuana.
Synopsis of Rule of Law.
“When discussing how reviewing courts should make reasonable-suspicion determinations, we have said repeatedly that they must look at the “totality of the circumstances” of each case to see whether the detaining officer has a ‘particularized and objective basis’ for suspecting legal wrongdoing.”
Facts.
A section of Highway 191 in Arizona serves as a border patrol checkpoint. Roving border agents check the unpaved back roads to catch smugglers who are seeking to avoid the checkpoint. Magnetic sensors lining the dirt roads alert agents to such smugglers. In January 1998, one Agent Stoddard was notified that a sensor had been triggered. Driving out to investigate, Stoddard encounter a minivan. It was the only vehicle Stoddard encountered. The minivan is a type of vehicle favored by drug-smugglers. A family of five occupied the van. Stoddard followed it after the driver appeared unnaturally stiff. The children began to wave in an “unnatural pattern” at Stoddard. After turning the last road to avoid the checkpoint, Stoddard radioed in for the vehicle’s registration, and then pulled the vehicle over upon learning that the owner lived in a high drug-traffic area. He asked the respondent, Ralph Arvizu, if he could search the van. He found over 100 lbs of marijuana in the
van.
Issue.
Whether certain factors, “alone . . . susceptible to innocent explanation, and some factors are more probative than others, taken together . . . sufficed to form a particularized and objective basis for stopping the vehicle” in compliance with the Fourth Amendment.
Held.
Yes. The court built its analysis on Terry’s reasonable-suspicion standard. In light of that, the Court reiterated that courts “must look at the ‘totality of the circumstances’ of each case to see whether the detaining officer has a ‘particularized and objective basis’ for suspecting legal wrongdoing.” This standard “allows officers to draw on their own experience and specialized training to make inferences from and deductions about the cumulative information available to them that ‘might well elude an untrained person.’” The appeals court erred by eliminating the seemingly innocuous behavior of the driver and the children, in light of the other circumstances, such as the van’s presence on a road know to smugglers without any overt reason and its evasion of the check point. “Stoddard was entitled to make an assessment of the situation in light of his specialized training and familiarity with the customs of the area’s inhabitants.” In conclusion, “having considered the tot
ality of the circumstances and given due weight to the factual inferences drawn by the law enforcement officer and District Court Judge, [the court held] that Stoddard had reasonable suspicion to believe that respondent was engaged in illegal activity.”
Concurrence. J. Scalia, agreed with the analysis of the court, but did not “see how deferring to the District Court’s factual inferences (as opposed to its findings of fact) is compatible with de novo review.”
Discussion.
“In making reasonable-suspicion determinations, reviewing courts must look at the “totality of the circumstances” of each case to see whether the detaining officer has a “particularized and objective basis” for suspecting legal wrongdoing.”
