People v. Flores, 546 P.3d 1114

Marlon Flores was detained by police in Los Angeles at night in an area known for narcotics and gang activity after officers observed him behaving evasively near a parked car.
Police saw Flores duck behind a car, where he then bent over and manipulated his hands near his shoe, ignoring officers' approach and commands to stand up.
After Flores was detained and searched, police discovered methamphetamine and a firearm. Flores moved to suppress that evidence, arguing the detention was unsupported by reasonable suspicion.
The trial court denied the motion to suppress, finding Flores's behavior sufficiently suspicious. The Court of Appeal affirmed, holding reasonable suspicion justified the detention.
The California Supreme Court granted review to determine if the detention was justified under the Fourth Amendment based on the totality of circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Flores’s detention was supported by reasonable suspicion under the Fourth Amendment	Police argued Flores’s evasive conduct in a high narcotics area justified suspicion of criminal activity	Flores argued his behavior was within his rights and did not amount to reasonable suspicion	Court held the detention was not justified—Flores’s conduct was odd but not reasonably indicative of criminal activity

Terry v. Ohio, 392 U.S. 1 (1968) (established the standard for investigative detentions based on reasonable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (2000) (nervous, evasive behavior may factor into reasonable suspicion, but mere avoidance is insufficient)
Florida v. Royer, 460 U.S. 491 (1983) (citizens are free to ignore police and go about their business unless there is reasonable suspicion)
United States v. Sokolow, 490 U.S. 1 (1989) (totality of circumstances governs determination of reasonable suspicion)
Brown v. Texas, 443 U.S. 47 (1979) (mere presence in a high-crime area insufficient for detention)