State v. Clink, 348 P.3d 1187

At 10:45 p.m., Officer Wolf responded to a named informant’s tip that “a couple of guys were in front of [an address] smoking something” in a silver Volvo; the caller gave a first name and phone number.
Wolf found the Volvo parked as described with two adults inside: defendant (driver) and a female passenger Wolf recognized as a methamphetamine user.
Wolf shone a spotlight from about 20–25 feet away and observed defendant make “elaborate,” “deliberate,” and “furtive” movements as if reaching into the glove box or center console concealing a large hard object.
Concerned about a weapon and drug use, Wolf called for backup, retained defendant’s license after asking for it, and ordered defendant out of the car; upon exiting Wolf saw a used meth pipe in the passenger’s pocket.
The passenger said the pipe belonged to defendant; after a backup officer obtained defendant’s consent to search, officers found methamphetamine in the center console. Defendant later admitted hiding the drugs.
Defendant moved to suppress, arguing the stop (ordering him out of the car) lacked reasonable suspicion; the trial court denied the motion and convicted him. The state conceded the encounter was a seizure but argued it was justified by reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer’s stop (ordering defendant out of car) was supported by reasonable suspicion under Art I, §9	Wolf (state): informant report of people “smoking something,” defendant’s furtive movements suggesting concealment of a weapon, and the passenger’s known meth use together supplied specific and articulable facts to justify a stop	Defendant: informant tip did not specify illegal activity and furtive gestures alone were insufficient; thus no reasonable suspicion existed and the stop was unlawful	Court held the totality of circumstances gave objectively reasonable suspicion and affirmed denial of suppression

State v. Ehly, 317 Or. 66 (discusses standard for reviewing suppression findings)
State v. Ashbaugh, 349 Or. 297 (defines stops and seizure justification under Article I, §9)
State v. Goss, 219 Or. App. 645 (reliable informant reports can supply specific and articulable facts)
State v. Greer, 93 Or. App. 409 (distinguishes bare reports of suspicious persons from tips conveying criminal activity)
State v. Wiseman, 245 Or. App. 136 (homeowner’s specific report may be considered with other circumstances)
State v. Holdorf, 355 Or. 812 (officer’s observations coupled with companion’s known involvement can support reasonable suspicion of drug possession)
State v. Rudnitskyy, 266 Or. App. 560 (furtive gestures can contribute to reasonable suspicion when combined with other facts)
State v. Miner, 240 Or. App. 175 (reasonable suspicion requires facts supporting a reasonable inference of illegal activity)