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.”
The Fourth Amendment prohibits unreasonable searches and seizures by the Government, and its protections extend to brief investigatory stops of persons or vehicles that fall short of traditional arrest.View Full Point of Law
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.”