District of Columbia v. R.W.
The Supreme Court reversed a D.C. appeals court ruling, holding that a police officer did have sufficient grounds to briefly stop a teenage driver whose two companions had just fled the car unprovoked when police arrived.
The per curiam opinion faults the D.C. court for breaking suspicious facts apart and dismissing them individually, rather than weighing them all together as the Fourth Amendment requires.
How it got here: The D.C. trial court denied R.W.'s request to suppress evidence; the D.C. Court of Appeals reversed and threw out the delinquency finding; D.C. asked the Supreme Court to step in, and the Court granted review summarily.
The Case in Depth
What happened
Around 2 a.m., a Washington, D.C. police officer responded to a dispatch call about a suspicious vehicle. When he pulled into the parking lot, two people immediately fled the car unprovoked. The driver, R.W. — a minor — then began backing out of the parking space with a rear door still hanging open. The officer ordered R.W. to stop. Police found evidence leading to charges of unauthorized vehicle use, receiving stolen property, and related offenses.
The question before the Court
Did a police officer have enough reason to briefly stop a teenage driver after two passengers bolted unprovoked from the car at the sight of police at 2 a.m.?
The Court's answer
Yes — the officer had sufficient grounds to make the stop. The Fourth Amendment allows a brief investigatory stop when an officer has a specific, objective reason to suspect criminal activity. The Court found the officer here had several: a dispatch call about a suspicious vehicle, the immediate unprovoked flight of two companions the moment police arrived, and R.W.'s own decision to back the car away without checking or closing the door his fleeing companions had left open.
The D.C. appeals court erred by removing — "excising" — the dispatch call and the companions' flight from its analysis before weighing the remaining facts, and then concluding those leftover facts weren't enough. The Supreme Court said that approach directly violates the rule that courts must look at the full picture together, not pick facts apart one by one and dismiss them in isolation.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Courts reviewing police stops must look at every suspicious fact together — a dispatch call, companions fleeing, a driver acting strangely — and cannot throw out individual factors before tallying the rest. The ruling reinforces that officers may act on the combined weight of circumstances even when no single detail alone would justify a stop.
What changes now
The case returns to the D.C. courts for further proceedings consistent with the Supreme Court's ruling. With the suppression motion reinstated as properly denied, R.W.'s earlier delinquency adjudication and one-year probation sentence may be restored, though the lower courts will resolve the details. This is a final merits ruling, not a temporary order.
What this does not decide
The Court did not decide whether the dispatch call alone, or the companions' flight alone, would have been enough to justify the stop. It also did not address how the totality-of-the-circumstances test applies when a bystander — rather than a co-occupant — flees near a suspect.
Concurrences and dissents
How the Justices voted
Dissent (2). Justice Jackson (author).
Dissent — Justice Jackson
Justice Jackson argued the summary reversal was unwarranted. In her view, the D.C. appeals court correctly understood the totality-of-the-circumstances test — its own precedents confirm that no single factor is decisive and that all must be weighed collectively. The word 'excised' was poor phrasing, she acknowledged, but did not reflect a genuine methodological error. Even if the lower court gave too little weight to the companions' flight, that routine, fact-specific disagreement did not justify the unusual step of summary reversal by the Supreme Court.
Dissent — Justice Sotomayor
Justice Sotomayor noted, in a single line, that she would have denied the petition for certiorari and not heard the case at all. She did not write a separate opinion explaining her reasoning. Read the full dissent →
How the Court got there
The legal reasoning, step by step
- The Fourth Amendment's *Terry stop* rule allows police to briefly detain someone without a formal arrest if the officer has 'reasonable articulable suspicion' that criminal activity may be underway. This is a lower bar than the probable cause needed for arrest, but still requires a specific, objective basis — not a hunch.
- The governing legal standard is the 'totality of the circumstances': courts must consider all available facts together as a whole picture. The Court's 2002 decision in *United States v. Arvizu* expressly forbids a 'divide-and-conquer' approach in which individual factors are evaluated and rejected in isolation before the rest are considered.
- The officer here had a strong combination of simultaneous signals: a dispatch call about a suspicious vehicle at that specific address; the immediate, unprovoked flight of two passengers the instant police pulled up — behavior the Court has previously called 'certainly suggestive' of wrongdoing; and R.W.'s own choice to put the car in reverse and drive away without so much as checking whether the door left open by his fleeing companions was closed.
- R.W.'s driving behavior mattered independently, not just as a byproduct of what his companions did. The Court reasoned that most drivers would not respond to passengers suddenly bolting by immediately backing away without closing a swinging door — the combination of panicked flight by companions and the driver's rushed departure strongly suggested all three were trying to hide wrongdoing from police.
- The D.C. appeals court committed a legal error by formally 'excising' the dispatch call and the companions' flight before analyzing the remaining facts. Stripping out what the Court called 'the most revealing aspect of the encounter' and then concluding the leftovers fell short was squarely incompatible with the totality-of-the-circumstances requirement.