On April 20, 2026, the United States Supreme Court decided the case of District of Columbia v. R.W. The principal issue concerned whether there was reasonable suspicion to justify the stop of the driver.
This was a per curiam opinion. Per curiam opinions are supposed to be reserved for cases with such a straightforward application of the law to the facts that no single judge has a basis to attach their unique analysis to it.
The Court wrote in relevant part: In the wee hours of a winter morning in Washington, D. C., District of Columbia Metropolitan Police Officer Clifford Vanterpool received a radio dispatch call directing him to check out a suspicious vehicle at a specific address. Officer Vanterpool reached the apartment building at that address around 2:00 a.m. As he turned his marked police vehicle into the parking lot, he saw two people immediately flee from a car, “unprovoked,” after “police had not done anything other than simply pull up.” App. to Pet. for Cert. 48a. The runners left open at least one of the car doors. The driver then began to back out of the parking space, rear door still open. Officer Vanterpool decided to investigate. He parked directly behind the car, left his own vehicle, ordered the driver, R. W., to put his hands up, and drew his service weapon. R. W. raised a “single argument” on appeal—that Officer Vanterpool lacked reasonable articulable suspicion sufficient to justify the seizure. In re R.W., 334 A. 3d 593, 599 (D. C. 2025).
The District of Columbia Court of Appeals held that Officer Vanterpool, by stopping R. W. without reasonable suspicion, violated the Fourth Amendment. We disagree. When an officer makes a “brief investigatory stop of persons or vehicles that falls short of a traditional arrest,” the Fourth Amendment “is satisfied 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)). In assessing whether an officer had reasonable suspicion, a reviewing court must “look at the ‘totality of the circumstances’ of each case”—an analysis that precludes the “evaluation and rejection” of “factors in isolation from each other.” Arvizu, 534 U. S., at 273–274. Because the D. C. Court of Appeals departed from these principles—and because Officer Vanterpool clearly had reasonable suspicion to stop R. W.—we reverse.
Largely based on evidence found after Officer Vanterpool told R. W. to put his hands up, the District of Columbia charged R. W. (a minor at the time) 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. Before trial, R. W. moved to suppress the evidence obtained after he was stopped. Following a suppression hearing, the trial court denied R.W.’s motion, relying on four facts to conclude that the officer had reasonable suspicion to stop R. W.: (1) the officer had received a radio dispatch call regarding a suspicious vehicle at a specified address, (2) the officer saw “‘two persons fleeing from a vehicle’” upon his arrival, (3) “‘it was almost 2 a.m.,’” and (4) as the officer approached the car, it began “‘backing out of the parking space while the rear driver’s side door was still open.’” 334 A. 3d, at 599. After a bench trial, the trial court adjudicated R. W. delinquent on all counts and assigned R. W. to one year of probation with conditions. On appeal, the D. C. Court of Appeals reversed the denial of the motion to suppress and vacated the delinquency adjudication.
The court “first assessed the legitimacy and The District of Columbia conceded that “Officer Vanterpool seized R. W. when he first asked R. W. to put his hands up,” so the D. C. Court of Appeals decided only whether the facts then known by Officer Vanterpool—before he ordered R. W. to put his hands up— warranted the stop. In other words, we ask whether Officer Vanterpool had a reasonable suspicion that R. W. was engaged in criminal wrongdoing. Sokolow, 490 U. S., at 7–8. 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 (quoting United States v. Cortez, 449 U. S. 411, 417 (1981)). Reasonable suspicion “‘depends on the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act.’” Kansas v. Glover, 589 U. S. 376, 380 (2020) (quoting Prado Navarette v. California, 572 U. S. 393, 402 (2014)). It permits officers to make “‘commonsense judgments and inferences about human behavior.’” Glover, 589 U. S., at 380–381 (quoting Illinois v. Wardlow, 528 U. S. 119, 125 (2000)).
On the facts of this case, Officer Vanterpool clearly had reasonable suspicion to stop R. W. Already on alert from the late-night dispatch call about a suspicious vehicle, the officer observed every person in R.W.’s car respond strangely to an approaching police car. Two people took off running. We have observed that “unprovoked flight upon noticing the police is certainly suggestive” of wrongdoing. Id., at 124. The driver, R.W., did not run from the car, but his companions’ flight cast his presence in a suspicious light. After all, we have observed 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)). We need not determine whether that connection alone supported reasonable suspicion because R. W. was in the driver’s seat and—after the passengers fled from the car— began backing out of the parking space, ignoring the car’s open back door. For most drivers, it would be a surprising event for their back-seat passengers to exit the car and run headlong away from them. But we doubt that most would respond by putting their car into reverse and attempting to drive away without at least checking whether the doors were closed. R. W.’s own actions—combined with the pan icked flight of his companions—strongly suggested that he was (like them) engaged in unlawful conduct he wished to hide from police. See Sibron v. New York, 392 U. S. 40, 66 (1968) (recognizing that “deliberately furtive actions and flight at the approach of law officers are strong indicia of mens rea”).
The D. C. Court of Appeals reached a different conclusion by “excising” the radio dispatch and the conduct of R. W.’s companions from the analysis, and considering only “the lateness of the hour and the slight movement of the car.” 334 A. 3d, at 597. The totality-of-the-circumstances test, however, “precludes this sort of divide-and-conquer analysis.” Arvizu, 534 U. S., at 274. As our precedents have recognized, “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). Indeed, this case reveals the perils of reviewing facts piecemeal and without context. Take the passengers’ flight from the car. We have little doubt that, in some circumstances, an officer could not reasonably attribute his suspicion of a fleeing individual to bystanders milling nearby. Cf. Ybarra v. Illinois, 444 U. S. 85, 91 (1979) (recognizing that “a person’s mere propinquity to others independently suspected of criminal activity does not, without more, give rise to probable cause to search that person”). But the “whole picture” here tells a different story. Cortez, 449 U. S., at 417. After watching two people flee from a suspicious car, a reasonable officer surely would question the driver’s next move. Why would the driver hurriedly back up the car without even closing a car door left open by his fleeing companions? Perhaps one could imagine an innocent explanation for such unusual behavior—the court below, for example, surmised that R. W. “may not even have noticed that his companions left the door open.” 334 A. 3d, at 605. “But we have consistently recognized that reasonable suspicion ‘need not rule out the possibility of innocent conduct.’” Navarette, 572 U. S., at 403 (quoting Arvizu, 534 U. S., at 277). Based on everything the officer observed on the night in question, he drew the “commonsense inference” that all three people in the car—including the driver—were trying to hide wrongdoing from the police. Glover, 589 U. S., at 381. “The Fourth Amendment requires that a court ‘slosh [its] way through’ a ‘factbound morass.’” Barnes v. Felix, 605 U. S. 73, 80 (2025) (quoting Scott v. Harris, 550 U. S. 372, 383 (2007)). There may be no “‘easy-to-apply legal test’” or “‘on/off switch’” in this context, Barnes, 605 U. S., at 80 (quoting Scott, 550 U. S., at 382–383), but one thing is clear: “The ‘totality of the circumstances’ requires courts to consider ‘the whole picture,’” Wesby, 583 U. S., at 60 (quoting Cortez, 449 U. S., at 417). The D.C. Court of Ap peals expressly declined to do that. 334 A. 3d, at 599.
It instead 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.” Id., at 605. Expressly “excised” from its analysis was, for example, the compelling fact that two individuals fled the vehicle as soon as they spotted the police car. Pretending that the most revealing aspect of the encounter did not happen is incompatible with the totality-of-the-circumstances approach re quired by our precedents.
The petition for certiorari and R. W.’s motion to proceed in forma pauperis are granted, the judgment of the District of Columbia Court of Appeals is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.
Confirming that this was not a true “per curiam” opinion, Justice Sotomayor voted to deny the petition and not consider the case. This would have left the Court of Appeal’s decision and dismissal in place. Further confirming that this was not a true “per curiam” opinion, Justice Jackson dissented. These two justices are widely-regarded as the most “liberal” justices.
Justice Jackson’s dissent criticized the majority’s decision to summarily reverse, arguing it was an improper use of high-court authority for a case involving many complicated facts. She believed more deference should have been given to the factual findings of the lower court. A fair critique of this dissent would be that it is the trial court that heard live testimony. Therefore, the trial court’s decision to deny the motion to suppress the evidence is the decision that deserves deference with regard to fact-finding. Justice Jackson defended the D.C. Court of Appeals’ application of the “totality-of-the-circumstances” test and objected to the majority’s “wordsmithing.”