In re R.W., 334 A.3d 593

Around 2:00 a.m., Officer Vanterpool responded to a dispatch about a “suspicious vehicle” and encountered R.W. in a parking lot, where two other individuals ran from the car as he approached.
Officer Vanterpool blocked the car from leaving, approached with his weapon drawn, and ordered R.W., the driver, to put his hands up, resulting in a Fourth Amendment seizure.
After the stop, officers discovered R.W. was 15 years old, the car had a damaged (punched) ignition, and it was reported stolen.
R.W. moved to suppress all evidence obtained after Officer Vanterpool ordered him to put his hands up, arguing that the seizure was unsupported by reasonable suspicion.
The trial court denied the motion, finding reasonable suspicion based on the dispatch, companions’ flight, late hour, and the car’s movement; R.W. was convicted and appealed.
The appellate court reversed, finding the seizure unlawful and ordering suppression of all evidence gathered following the seizure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there reasonable suspicion for the stop?	Officer lacked reasonable suspicion; facts insufficient under the Fourth Amendment.	Facts (dispatch, flight, late hour, car movement) created reasonable suspicion.	No reasonable suspicion; dispatch and flight of others not valid factors here.
Should companions’ flight be imputed to R.W.?	Only suspicious joint involvement can justify imputing flight.	Mere association in car is enough for suspicion.	No, mere association does not permit imputation; no evidence of joint venture.
Was the radio dispatch properly relied upon?	Dispatch unsupported by reliable detail cannot support suspicion.	Dispatch alerted officer to potential criminal activity.	No, dispatch lacked specificity and reliability regarding suspicious conduct.
Should exclusionary rule exceptions apply?	Suppression required under the Fourth Amendment.	Exceptions (plain view, inevitable discovery) make evidence admissible.	Suppression affirmed; government waived exceptions by not raising them at trial.

Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable suspicion standard for stops under the Fourth Amendment)
In re T.L.L., 729 A.2d 334 (D.C. 1999) (holds reliability of police dispatch information is essential for reasonable suspicion)
Kansas v. Glover, 589 U.S. 376 (2020) (sets the level of proof needed for reasonable suspicion)
Whitely v. Warden, 401 U.S. 560 (1971) (police dispatches must be based on reliable information to justify stops)
Illinois v. Wardlow, 528 U.S. 119 (2000) (flight may be considered in reasonable suspicion when contextually suspicious)
Ybarra v. Illinois, 444 U.S. 85 (1979) (mere presence at crime scene, without more, is insufficient for reasonable suspicion)