State v. Walker, 372 P.3d 540

Shortly before noon a named informant called dispatch saying he observed what he believed to be a drug deal in a George Fox University parking lot: a white van driven by a woman, a man on a bicycle who entered the van, pulled something from his pants, both looked at it in his lap, then "were smoking something." The informant described the van and the bicyclist’s red sweatshirt and black hat.
Officer McCowan arrived within minutes; the woman drove off and the bicyclist (defendant) exited the van and walked toward his bicycle. McCowan observed that defendant matched the informant’s description.
McCowan stopped and questioned defendant; defendant refused a search. After learning defendant was on probation, McCowan obtained a judge’s order to search; defendant was arrested and admitted he had methamphetamine.
At the suppression hearing the state conceded a detention occurred but argued McCowan had reasonable suspicion based on the informant’s report, McCowan’s observations, and McCowan’s training and experience. The trial court denied suppression; defendant was convicted after a stipulated-facts bench trial.
On appeal the defendant argued the informant’s conclusory claim of a "drug deal" could not supply reasonable suspicion absent evidence that laypeople can reliably recognize drug deals; the state argued the totality of the circumstances (informant, officer observations, officer training) supplied reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer had reasonable suspicion to stop/detain defendant	State: yes — informant was identified, reported observed facts, officer’s observations corroborated, and officer’s training allowed inference of a drug transaction	Defendant: no — informant’s conclusory label (“drug deal”) is not probative absent common-knowledge ability to identify drug deals; remaining facts alone were insufficient	Held: Yes. The totality of the circumstances (reliable informant’s observations and conclusion, corroboration by officer, and officer’s training/experience) gave reasonable suspicion to justify the stop.

State v. Holdorf, 355 Or. 812 (2014) (defines reasonable suspicion standard; permits reliance on officer inferences grounded in articulable facts and pertinent training/experience)
State v. Ehly, 317 Or. 66 (1993) (standard of review for suppression hearings; trial-court factual findings binding if supported)
State v. Valdez, 277 Or. 621 (1977) (officer cannot detain based on mere hunch; need observable facts)
State v. Fair, 353 Or. 588 (2013) (distinguishes encounter, stop, and arrest; stops require reasonable suspicion)
State v. Mitchele, 240 Or. App. 86 (2010) (reliable informant’s conclusion may be considered in totality for reasonable suspicion)
State v. Lichty, 313 Or. 579 (1992) (lay informant’s identification of cocaine may be relied on where members of society have common knowledge of the drug’s appearance)
State v. Clink, 270 Or. App. 646 (2015) (informant’s report that parties were “smoking something” may contribute to reasonable suspicion when combined with other corroborating facts)