State v. Worthington, 335 P.3d 348

Late-night knife robbery occurred at a Seaside video store; dispatch described suspect as stocky male, 5'4"–5'7", wearing black. Multiple agencies responded and established a "rolling perimeter."
About 45 minutes later Officer Pohl in an unmarked car observed defendant ~75 yards from the store in a dim area accessible by alleys; defendant emerged suddenly from behind a parked van.
Defendant was ~5'7" and wore a light-colored sweatshirt (not the dark clothing in the description); he appeared nervous and gave an account the officer found inconsistent with other observations.
Pohl stopped and spoke with defendant, retained his identification, and (after consent to a patdown) found large amounts of cash; defendant later confessed to the robbery.
Defendant moved to suppress the cash and confession, arguing the stop lacked reasonable suspicion under Article I, section 9 of the Oregon Constitution; the trial court denied the motion and defendant appealed only the state-constitutional stop issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable suspicion to stop defendant under Article I, §9	Officer points to proximity to scene, emergence from behind van, height matching dispatch, nervousness, inconsistent story, and officer experience with suspects changing clothes	Stop lacked reasonable suspicion because defendant did not match clothing/body-type description and remaining facts were individually insufficient	Court held the totality of circumstances gave objective reasonable suspicion; stop was lawful

State v. Ehly, 317 Or 66 (discusses standards for reasonable suspicion and articulable facts)
State v. Fair, 353 Or 588 (defines investigatory "stops")
State v. Jones, 245 Or App 186 (two-part reasonable-suspicion analysis)
State v. Cloman, 254 Or 1 (reasonable suspicion requires connection to criminal activity)
State v. Berry, 232 Or App 612 (totality-of-circumstances inquiry)
State v. Wiseman, 245 Or App 136 (aggregating facts in totality analysis)
State v. Greer, 93 Or App 409 (only facts known before stop considered)
State v. Brown, 229 Or App 294 (officer need only reasonably believe conduct justified)
State v. Miller, 345 Or 176 (officer's reasonable belief standard)
State v. Dampier, 244 Or App 547 (facts need only support reasonable inference of illegal activity)
State v. Richards, 57 Or App 140 (discrepancies from suspect description do not necessarily negate reasonable suspicion)
State v. Ragsdale, 34 Or App 549 (similar principle regarding descriptive mismatches)