reasonable suspicion standard (Kansas) · Go Syfert
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reasonable suspicion standard in Kansas

24 Kansas opinions name it 2 courts 2000–2026 9 in the last five years

The cases below were cited by Kansas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
Terry v. Ohiogreen
scotus · 1968 · cited in 3 Kansas opinions naming this issue, 2017–2025
2 sentences

2025See Terry, 392 U.S. at 21-22 (noting that the objective standard of reasonable suspicion requires the court to ask whether the facts available to the officer at the moment of seizure or search would warrant a person of reasonable caution to believe the search or seizure was appropriate); Jones, 300 Kan. at 645 (an officer is not required to neatly package the reasonable suspicion factors in a single succinct answer; the court is required to consider 'the totality of the circumstances, all facts and inferences, [and] not a select few')." Cash, 313 Kan. at 130.

2021See Terry, 392 U.S. at 21-22 (noting that the objective standard of reasonable suspicion requires the court to ask whether the facts available to the officer at the moment of seizure or search would warrant a person of reasonable caution to believe the search or seizure was appropriate); Jones, 300 Kan. at 645 (an officer is not required to neatly package the reasonable suspicion factors in a single succinct answer; the court is required to consider "the totality of the circumstances, all facts and inferences, [and] not a select few").

23
State v. Jonesgreen
kan · 2014 · cited in 2 Kansas opinions naming this issue, 2021–2025
2 sentences

2025Jones, 300 Kan. at 637 ; see K.S.A. 22-2402(1).

2021See Terry, 392 U.S. at 21-22 (noting that the objective standard of reasonable suspicion requires the court to ask whether the facts available to the officer at the moment of seizure or search would warrant a person of reasonable caution to believe the search or seizure was appropriate); Jones, 300 Kan. at 645 (an officer is not required to neatly package the reasonable suspicion factors in a single succinct answer; the court is required to consider "the totality of the circumstances, all facts and inferences, [and] not a select few").

12
United States v. Arvizugreen
scotus · 2002 · cited in 2 Kansas opinions naming this issue, 2020–2022
2 sentences

2022See Arvizu, 534 U.S. at 274-75 (noting 19 Court has "deliberately avoided reducing [the reasonable suspicion standard] to '"a neat set of legal rules"'" but observing that "[e]ven if in many instances the factual 'mosaic' analyzed for a reasonable-suspicion determination would preclude one case from squarely controlling another, 'two decisions when viewed together may usefully add to the body of law on the subject'").

2020Recognizing that sometimes the distinction between probable cause and reasonable suspicion is blurred, the Supreme Court clarified that "[t]he reasonable suspicion inquiry 'falls considerably short' of 51% accuracy, see United States v. Arvisu, 534 U.S. 266, 274 , 122 S. Ct. 744 , 151 L.

12
Illinois v. Wardlowgreen
scotus · 2000 · cited in 1 Kansas opinions naming this issue, 2025–2025
2 sentences

2025See Illinois v. Wardlow, 528 U.S. 119, 124 , 120 S. Ct. 673 , 145 L.

2025See Illinois v. Wardlow, 528 U.S. 119, 124 , 120 S. Ct. 673 , 145 L.

11
State v. Cashgreen
kan · 2021 · cited in 1 Kansas opinions naming this issue, 2022–2022
1 sentence

2022See State v. Cash, 313 Kan. 121 , 130, 483 P.3d 1047 (2021) ("The reasonable suspicion analysis requires use of an objective standard based on the totality of the circumstances, not a subjective standard based on the detaining officer's personal belief.").

11
Mackie L. Shivers, Jr. v. USAgreen
ca11 · 2021 · cited in 1 Kansas opinions naming this issue, 2022–2022
1 sentence

2022Cf. Shivers, 1 F.4th at 931 (Eighth Amendment contains no specific directive as to inmate classifications or housing placements and plaintiff's allegations of an Eighth Amendment violation cannot demonstrate a breach of a mandatory duty sufficient to overcome discretionary function immunity under the FTCA).

11
Whren v. United Statesgreen
scotus · 1996 · cited in 1 Kansas opinions naming this issue, 2021–2021
2 sentences

2021See Whren v. United States, 517 U.S. 806, 813 , 116 S. Ct. 1769 , 135 L.

2021See Whren v. United States, 517 U.S. 806, 813 , 116 S. Ct. 1769 , 135 L.

11
State v. Lowerygreen
kan · 2018 · cited in 1 Kansas opinions naming this issue, 2019–2019
2 sentences

2019State v. Lowery , 308 Kan. 359 , 370, 420 P.3d 456 (2018).

2019See, e.g., Lowery , 308 Kan. at 370, 420 P.3d 456 (finding no reasonable suspicion to extend the stop when the driver was nervous, a minor discrepancy was shown between the driver's and passenger's accounts of the pair's travels, and the two were traveling in a rented car); State v. Messner , 55 Kan.

11
Rodriguez v. United Statesgreen
scotus · 2015 · cited in 1 Kansas opinions naming this issue, 2019–2019
2 sentences

2019The State took the position that the reasonable suspicion framework of how long an officer can detain for a drug dog has been "sort of foreclosed under Rodriguez [ v. United States , 575 U.S. 348 , 135 S. Ct. 1609 , 191 L.

2019The State took the position that the reasonable suspicion framework of how long an officer can detain for a drug dog has been "sort of foreclosed under Rodriguez [ v. United States , 575 U.S. 348 , 135 S. Ct. 1609 , 191 L.

11
United States v. Ludwiggreen
ca10 · 2011 · cited in 1 Kansas opinions naming this issue, 2018–2018
2 sentences

2018The State also cites United States v. Ludwig, 641 F.3d 1243, 1249 (10th Cir. 2011), in which the court recognized this could be at least relevant to a reasonable suspicion analysis depending on circumstances.

2018The State also cites United States v. Ludwig , 641 F.3d 1243 , 1249 (10th Cir. 2011), in which the court recognized this could be at least relevant to a reasonable suspicion analysis depending on circumstances.

11
United States v. Sylvester Townsend and David Greengreen
ca6 · 2002 · cited in 1 Kansas opinions naming this issue, 2018–2018
2 sentences

2018But in United States v. Townsend, 305 F.3d 537, 544 (6th Cir. 2002), there were "three cellular telephones in the passenger compartment" and the officers claimed the presence of multiple phones "was typical of drug couriers." The Sixth Circuit reasoned, "Three cell phones in one car does seem slightly odd, and we are certainly not prepared to hold that the presence of several cell phones cannot contribute to reasonable suspicion . . . .

2018But in United States v. Townsend , 305 F.3d 537 , 544 (6th Cir. 2002), there were "three cellular telephones in the passenger compartment" and the officers claimed the presence of multiple phones "was typical of drug couriers." The Sixth Circuit reasoned, "Three cell phones in one car does seem slightly odd, and we are certainly not prepared to hold that the presence of several cell phones cannot contribute to reasonable suspicion ....

11
United States v. Terrence Vaughangreen
ca4 · 2012 · cited in 1 Kansas opinions naming this issue, 2018–2018
2 sentences

2018In United States v. Vaughan , 700 F.3d 705 , 712 (4th Cir. 2012), there were four phones in a car containing two people, at least two "of the pre-paid type known to the detaining officer to be associated with narcotics trafficking." The Fourth Circuit held "the presence of the phones constitute[d] a valid factor in a reasonable suspicion analysis." 700 F.3d at 712 .

2018In United States v. Vaughan , 700 F.3d 705 , 712 (4th Cir. 2012), there were four phones in a car containing two people, at least two "of the pre-paid type known to the detaining officer to be associated with narcotics trafficking." The Fourth Circuit held "the presence of the phones constitute[d] a valid factor in a reasonable suspicion analysis." 700 F.3d at 712 .

11
Dennis v. Stategreen
fladistctapp · 2006 · cited in 1 Kansas opinions naming this issue, 2011–2011
1 sentence

2011The warrant supplies the officers with probable cause to arrest the person it names and describes, not a license to duck the reasonable suspicion requirement and stop someone they only have a subjective hunch is that person.”); Dennis v. State, 927 So. 2d 173, 175 (Fla. Dist.

11
United States v. Trujillogreen
ca10 · 2005 · cited in 1 Kansas opinions naming this issue, 2009–2009
1 sentence

2009See Moore, 283 Kan. at 354 (explaining the reasonable suspicion standard); see also United States v. Trujillo, 404 F.3d 1238, 1244-45 (10th Cir. 2005) (upholding the search of a parolee’s residence where the parolee failed a drug test 4 months prior to the search, refused a drug test 1 day before the search, and a de *212 tective had information from unknown sources that the parolee may be involved in drug dealing); State v. Uhlig, 38 Kan.

11
State v. Mooregreen
kan · 2007 · cited in 1 Kansas opinions naming this issue, 2009–2009
1 sentence

2009See Moore, 283 Kan. at 354 (explaining the reasonable suspicion standard); see also United States v. Trujillo, 404 F.3d 1238, 1244-45 (10th Cir. 2005) (upholding the search of a parolee’s residence where the parolee failed a drug test 4 months prior to the search, refused a drug test 1 day before the search, and a de *212 tective had information from unknown sources that the parolee may be involved in drug dealing); State v. Uhlig, 38 Kan.

11
United States v. Terry L. Woodgreen
ca10 · 1997 · cited in 1 Kansas opinions naming this issue, 2007–2007
1 sentence

2007The DeMarco court discussed the role “nervousness” plays in the reasonable suspicion inquiry: “ It is certainly not uncommon for most citizens — whether innocent or guiliy — to exhibit signs of nervousness when confronted by a law enforcement officer. [Citations omitted.]’ ” 263 Kan. at 736 (quoting United States v. Wood, 106 F.3d 942, 948 [10th Cir. 1997]).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
United States v. Knights green
scotus · 2001
2 sentences

2018Knights , 534 U.S. at 119 -21 , 122 S.Ct. 587 .

2008In Knights , the Supreme Court extended its holding in Griffin to authorize the use of the reasonable suspicion standard by general law enforcement officers. 534 U.S. at 120-22 .

22008–2018
Griffin v. Wisconsin green
scotus · 1987
2 sentences

2009It should be emphasized that the Court found it unnecessary to consider whether any search of a probationer’s home (by community corrections or law enforcement officers) need only satisfy a reasonable suspicion standard, because the type of searches challenged were “carried out pursuant to a regulation that itself satisfies the Fourth Amendment’s reasonableness requirement.” 483 U.S. at 887 .

2008Thus, the Griffin Court upheld Wisconsin’s use of a reasonable suspicion standard to justify probationer searches by their probation officers. 483 U.S. at 877-80 .

22008–2009
State v. McGinnis green
kanctapp · 2008
1 sentence

2026App. 2d 620, 628 , 194 P.3d 46 (2008) (12-pack of beer in front seat considered as part of a reasonable suspicion analysis).

12026–2026
State v. Bates neutral
kan · 2022
1 sentence

2026To satisfy a reasonable suspicion standard, the officer "'must have a particularized and objective basis for suspecting the particular person stopped of criminal activity.'" State v. Bates, 316 Kan. 174 , 183, 513 P.3d 483 (2022).

12026–2026
Kansas v. Glover green
scotus · 2020
2 sentences

2026"The reasonable suspicion inquiry 'falls considerably short' of 51% accuracy." Glover, 589 U.S. at 381 .

2026"The reasonable suspicion inquiry 'falls considerably short' of 51% accuracy." Glover, 589 U.S. at 381 .

12026–2026
United States v. Cortez green
scotus · 1981
1 sentence

2022Based upon that whole picture the detaining officers must have a particularized and objective basis for suspecting the particular person stopped of criminal activity." Cortez, 449 U.S. at 417-18 .

12022–2022
State v. Andrade-Reyes green
kan · 2019
1 sentence

2022State v. Andrade-Reyes, 309 Kan. 1048 , 1057, 442 P.3d 111 (2019).

12022–2022
Kansas v. Glover green
scotus · 2020
2 sentences

2021Reasonable suspicion "'depends on the factual and practical considerations of everyday life on which reasonable and prudent [people], not legal technicians, act.' [Citations omitted.]" State v. Glover, 589 U.S. ___ , 140 S. Ct. 1183, 1188 , 206 L.

2021Reasonable suspicion "'depends on the factual and practical considerations of everyday life on which reasonable and prudent [people], not legal technicians, act.' [Citations omitted.]" State v. Glover, 589 U.S. ___ , 140 S. Ct. 1183, 1188 , 206 L.

12021–2021
State v. Messner green
kanctapp · 2018
2 sentences

2019See, e.g., Lowery , 308 Kan. at 370, 420 P.3d 456 (finding no reasonable suspicion to extend the stop when the driver was nervous, a minor discrepancy was shown between the driver's and passenger's accounts of the pair's travels, and the two were traveling in a rented car); State v. Messner , 55 Kan.

2019See, e.g., Lowery, 308 Kan. at 370 (finding no reasonable suspicion to extend the stop when the driver was nervous, a minor discrepancy was shown between the driver's and passenger's accounts of the pair's travels, and the two were traveling in a rented car); State v. Messner, 55 Kan.

12019–2019
State v. Schooler green
kan · 2018
1 sentence

2019Schooler , 308 Kan. at 351-52, 419 P.3d 1164 .

12019–2019
State v. Martinez green
kan · 2013
1 sentence

2017Martinez, 296 Kan. at 487 .

12017–2017
State v. Uhlig neutral
kanctapp · 2007
2 sentences

2009See Moore, 283 Kan. at 354 (explaining the reasonable suspicion standard); see also United States v. Trujillo, 404 F.3d 1238, 1244-45 (10th Cir. 2005) (upholding the search of a parolee’s residence where the parolee failed a drug test 4 months prior to the search, refused a drug test 1 day before the search, and a de *212 tective had information from unknown sources that the parolee may be involved in drug dealing); State v. Uhlig, 38 Kan.

2009App. 2d 610, 614-17 , 170 P.3d 894 (2007), rev. denied 286 Kan. 1185 (2008) (upholding the search of a juvenile probationer s bedroom where a court services officer stopped by for a random compliance visit, the probationer consented to a bedroom search but then attempted to delay the officers from entering his bedroom, and the probationer admitted that he had tried to hide contraband in his room).

12009–2009
Sampson v. United States green
scotus · 2006
1 sentence

2007That concern applies with even greater force to a system of supervising parolees.” 547 U.S. at 854 .

12007–2007
State v. Ramirez green
kan · 2004
1 sentence

2006“Where one or two factors may cause a reasonable suspicion, a combination of several factors may create probable cause.” Ramirez, 278 Kan. at 407 .

12006–2006
State v. Finley green
kanctapp · 1992
12000–2000

Statutes the citing opinions construe

KS § K.S.A. § 22-2402 (9) KS § K.S.A. § 20-3018 (6) KS § K.S.A. § 22-3216 (6) KS § K.S.A. § 60-2101 (4) KS § K.S.A. § 79-5208 (3) KS § K.S.A. § 8-1567 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 230 (1988–2026) PA 147 (1983–2026) ID 145 (1994–2026) MN 86 (1980–2026) CA 82 (1962–2026) OH 80 (1990–2026) IN 80 (1993–2026) NC 73 (1981–2026) MA 59 (1990–2026) OR 53 (1978–2026) NM 51 (1993–2024) NJ 50 (1986–2026) WI 50 (1987–2026) VA 50 (1987–2026) IL 47 (1990–2025) FL 44 (1981–2025) MD 43 (1974–2026) NY 41 (1978–2026) UT 29 (1983–2020) IA 27 (1997–2025) ND 27 (1986–2024) CO 27 (1983–2026) KS 24 (2000–2026) SD 23 (1983–2026) WA 21 (1989–2021) KY 19 (1991–2024) MO 19 (1989–2021) ME 18 (1987–2022) TN 18 (1992–2019) LA 17 (1993–2025) AZ 16 (2004–2025) WV 15 (1985–2024) DE 14 (2001–2024) MI 13 (1980–2025) DC 13 (2000–2025) WY 12 (2007–2025) GA 12 (1998–2020) CT 9 (1988–2017) VT 9 (1998–2020) SC 8 (2000–2025) AK 7 (1988–2025) HI 6 (1994–2009) NE 6 (1978–2023) NH 4 (2004–2020) MS 4 (2005–2011) RI 4 (1980–2024) NV 4 (2015–2019) AL 3 (1993–2026) AR 3 (2000–2015) MT 2 (2000–2006) OK 2 (2019–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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