District of Columbia v. R.W.

Summary

In a per curiam summary reversal, the Supreme Court held that a D.C. police officer had reasonable articulable suspicion to stop a minor driver, R.W., at 2:00 a.m. after two passengers unprovoked fled the car and the driver began backing out with a rear door still open. The District of Columbia Court of Appeals had reversed the suppression denial by 'excising' the radio dispatch call and the passengers' flight from its analysis, leaving only the late hour and the brief reverse movement. The Supreme Court held that approach incompatible with the totality-of-the-circumstances test set out in Arvizu and Wardlow: reviewing courts may not divide-and-conquer facts to defeat reasonable suspicion. Viewed together, the late-night dispatch, the unprovoked flight of the passengers, and R.W.'s unusual response (backing up with an open door) gave Officer Vanterpool a commonsense, particularized basis to suspect criminal activity. Justice Jackson dissented, arguing that the D.C. court applied the correct test and that the majority's intervention was an unwarranted act of word-smithing a lower court on a fact-bound record. Justice Sotomayor would have denied certiorari.

Structured facts

Parties

Petitioner/Appellant: District of Columbia
Respondent/Appellee: R.W. (a minor)

Jurisdiction

federal — U.S. Supreme Court on certiorari from the District of Columbia Court of Appeals

Statutes cited

U.S. Const. amend. IV

Issue

Whether a D.C. police officer had reasonable articulable suspicion under the Fourth Amendment to make an investigatory stop based on the totality of the circumstances at the scene.

Holding

Yes. The totality-of-the-circumstances test precludes a divide-and-conquer analysis; viewed together, the dispatch call, the unprovoked passenger flight, and R.W.'s unusual driving behavior established reasonable suspicion.

Outcome

reversed and remanded

Vote

per curiam; Sotomayor would deny cert; Jackson dissents

Majority author

Per Curiam

Key facts

• Around 2:00 a.m., Officer Vanterpool responded to a radio dispatch about a suspicious vehicle at a specified address.
• When he arrived, two people immediately fled from the car, leaving at least one door open.
• R.W., the driver, began backing out of the parking space with the rear door still open.
• The officer stopped the car, ordered R.W. to put his hands up, and drew his weapon; evidence recovered after the stop supported four vehicle-related delinquency charges.
• The trial court denied suppression; the D.C. Court of Appeals reversed, excising the dispatch call and passenger flight from its analysis and finding no reasonable suspicion.

Reasoning

Citing Arvizu, Sokolow, Wardlow, Glover, and Wesby, the per curiam reiterated that reasonable suspicion is assessed holistically. Unprovoked flight is 'certainly suggestive' of wrongdoing, and a driver's choice to reverse with an open door after his passengers flee supports a commonsense inference of shared criminal purpose. The D.C. Court of Appeals erred by removing facts from its analysis rather than weighing them together; pretending the most revealing fact (the flight) did not happen was incompatible with settled Fourth Amendment doctrine.

Implications

The opinion is short and fact-bound, but it is a strong signal to lower courts — especially state and D.C. appellate courts — about how totality-of-the-circumstances review is supposed to work in Fourth Amendment stop cases. Three implications stand out. First, appellate courts cannot 'excise' individual facts from the reasonable-suspicion calculus on the theory that each fact, standing alone, is innocuous. The whole picture governs. Second, SCOTUS is willing to use summary reversal to police lower-court methodology in this area, even where the disputed record is narrow; that changes the risk calculus for defense counsel deciding whether to invite certiorari on fact-bound Fourth Amendment wins. Third, the per curiam reaffirms that unprovoked flight of companions casts the driver's own conduct in a more suspicious light — a doctrinal move that connects Wardlow (flight of the suspect) to shared-enterprise inferences from Houghton and Pringle. Justice Jackson's dissent raises a methodological counter-point worth watching: her argument that factor-by-factor opinion writing is not the same as 'divide-and-conquer' analysis could become a rallying point for future lower-court defenses of structured Fourth Amendment reasoning.

Related cases

• United States v. Arvizu, 534 U.S. 266 (2002) — totality-of-the-circumstances test
• Illinois v. Wardlow, 528 U.S. 119 (2000) — unprovoked flight from police as a factor
• United States v. Sokolow, 490 U.S. 1 (1989) — reasonable suspicion standard
• District of Columbia v. Wesby, 583 U.S. 48 (2018) — whole-picture rule
• Kansas v. Glover, 589 U.S. 376 (2020) — commonsense inferences in reasonable suspicion

Practical guide

For defense attorneys: after R.W., it is harder to win a suppression argument by attacking individual factors in isolation. Prepare to contest the whole picture, including facts the officer says put the client on alert (dispatch calls, companions' behavior, time of night). Focus on whether the officer had a particularized basis — not generalized profile — for the stop. For prosecutors: lean on totality-of-the-circumstances framing and cite R.W.'s rebuke of 'excision' when opposing suppression motions. For D.C. and state appellate judges: a factor-by-factor opinion is fine, but the final assessment must explicitly aggregate the factors; avoid words like 'excise' or 'disregard' when discussing individual facts. For civil-rights plaintiffs pursuing Section 1983 claims, the ruling tightens the reasonable-suspicion bar at the front end — but leaves open the post-Barnes v. Felix (2025) analysis for any subsequent use-of-force claims.

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