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16 Arizona opinions name it 2 courts 2004–2025 3 in the last five years
The cases below were cited by Arizona 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.
| Case | Followed | Cited |
|---|---|---|
United States v. Sokolowgreen2 sentences2025“Although a mere ‘hunch’ does not create reasonable suspicion, the level of suspicion the standard requires is considerably less than proof of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for probable cause.” Kansas v. Glover, 589 U.S. 376, 380 (2020) (quoting Prado Navarette v. California, 572 U.S. 393, 397 (2014) (quotation altered)); see also Sokolow, 490 U.S. at 7 . ¶18 Relevant here, the Arizona Legislature codified the reasonable suspicion standard for traffic violations in A.R.S. § 28-1594: “A peace officer or duly authorized agent of a traffic enf 2025“Although a mere ‘hunch’ does not create reasonable suspicion, the level of suspicion the standard requires is considerably less than proof of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for probable cause.” Kansas v. Glover, 589 U.S. 376 , 380 (2020) (quoting Prado Navarette v. California, 572 U.S. 393, 397 (2014) (quotation altered)); see also Sokolow, 490 U.S. at 7 . ¶18 Relevant here, the Arizona Legislature codified the reasonable suspicion standard for traffic violations in A.R.S. § 28-1594: “A peace officer or duly authorized agent of a traffic en | 4 | 5 |
Terry v. Ohiogreen2 sentences2018The Court also noted that the reasonable belief standard was the same as the reasonable suspicion standard discussed in Terry v. Ohio, 392 U.S. 1 (1968) and Michigan v. Long, 463 U.S. 1032 (1983). 2015“The Fourth Amendment requires ‘some minimal level of objective justification’ for making the stop.” Id. (quoting INS v. Delgado, 466 U.S. 210, 217 , 104 S.Ct. 1758 , 80 L.Ed.2d 247 (1984)). ¶ 8 Courts have struggled to articulate when evidence rises to a level that satisfies the reasonable suspicion standard. | 3 | 8 |
Immigration & Naturalization Service v. Delgadogreen2 sentences2017Reasonable Suspicion ¶7 Mortemore argues that his presence in an alley did not create a reasonable suspicion that he was involved in criminal behavior. ¶8 Although the reasonable suspicion standard affords flexibility, investigatory stops cannot be arbitrary: “[t]he Fourth Amendment requires ‘some minimal level of objective justification’ for making the stop.” United States v. Sokolow, 490 U.S. 1, 7 (1989) (quoting INS v. Delgado, 466 U.S. 210, 217 (1984)). 2015“The Fourth Amendment requires ‘some minimal level of objective justification’ for making the stop.” Id. (quoting INS v. Delgado, 466 U.S. 210, 217 , 104 S.Ct. 1758 , 80 L.Ed.2d 247 (1984)). ¶ 8 Courts have struggled to articulate when evidence rises to a level that satisfies the reasonable suspicion standard. | 2 | 3 |
Prado Navarette v. Californiagreen2 sentences2025“Although a mere ‘hunch’ does not create reasonable suspicion, the level of suspicion the standard requires is considerably less than proof of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for probable cause.” Kansas v. Glover, 589 U.S. 376, 380 (2020) (quoting Prado Navarette v. California, 572 U.S. 393, 397 (2014) (quotation altered)); see also Sokolow, 490 U.S. at 7 . ¶18 Relevant here, the Arizona Legislature codified the reasonable suspicion standard for traffic violations in A.R.S. § 28-1594: “A peace officer or duly authorized agent of a traffic enf 2025“Although a mere ‘hunch’ does not create reasonable suspicion, the level of suspicion the standard requires is considerably less than proof of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for probable cause.” Kansas v. Glover, 589 U.S. 376 , 380 (2020) (quoting Prado Navarette v. California, 572 U.S. 393, 397 (2014) (quotation altered)); see also Sokolow, 490 U.S. at 7 . ¶18 Relevant here, the Arizona Legislature codified the reasonable suspicion standard for traffic violations in A.R.S. § 28-1594: “A peace officer or duly authorized agent of a traffic en | 2 | 2 |
State v. Sweeneygreen2 sentences2015Reasonable suspicion for traffic stops cannot rest solely on “circumstances or factors that do not reliably distinguish between suspect and innocent behaviors ... because they may cast too wide a net and subject all travelers to ‘virtually random seizures.’” State v. Sweeney, 224 Ariz. 107, ¶ 22 , 227 P.3d 868, 874 (App.2010), quoting Reid v. Georgia, 448 U.S. 438, 441 , 100 S.Ct. 2752 , 65 L.Ed.2d 890 (1980) (per curiam). 2015Reasonable suspicion for traffic stops cannot rest solely on “circumstances or factors that do not reliably distinguish between suspect and innocent behaviors ... because they may cast too wide a net and subject all travelers to ‘virtually random seizures.’” State v. Sweeney, 224 Ariz. 107, ¶ 22 , 227 P.3d 868, 874 (App.2010), quoting Reid v. Georgia, 448 U.S. 438, 441 , 100 S.Ct. 2752 , 65 L.Ed.2d 890 (1980) (per curiam). | 2 | 2 |
Ornelas v. United Statesgreen2 sentences2015See Ornelas v. United States, 517 U.S. 690, 695 , 116 S.Ct. 1657 , 134 L.Ed.2d 911 (1996) (noting that “[a]rticulating precisely what ‘reasonable suspicion’ and ‘probable cause’ mean is not possible”). 2015See Ornelas v. United States, 517 U.S. 690, 695 , 116 S.Ct. 1657 , 134 L.Ed.2d 911 (1996) (noting that “[a]rticulating precisely what ‘reasonable suspicion’ and ‘probable cause’ mean is not possible”). | 2 | 2 |
State v. Buccinigreen2 sentences2015See State v. Dupuy, 116 Ariz. 151, 155 , 568 P.2d 1049, 1053 (1977); see also Buccini, 167 Ariz. at 557 , 810 P.2d at 185 . ¶9 When assessing probable cause, comparison to the reasonable-suspicion standard is instructive. 2015See State v. Dupuy, 116 Ariz. 151, 155 , 568 P.2d 1049, 1053 (1977); see also Buccini, 167 Ariz. at 557 , 810 P.2d at 185 . ¶ 9 When assessing probable cause, comparison to the reasonable-suspicion standard is instructive. | 2 | 2 |
State v. Dupuygreen2 sentences2015See State v. Dupuy, 116 Ariz. 151, 155 , 568 P.2d 1049, 1053 (1977); see also Buccini, 167 Ariz. at 557 , 810 P.2d at 185 . ¶ 9 When assessing probable cause, comparison to the reasonable-suspicion standard is instructive. 2015See State v. Dupuy, 116 Ariz. 151, 155 , 568 P.2d 1049, 1053 (1977); see also Buccini, 167 Ariz. at 557 , 810 P.2d at 185 . ¶ 9 When assessing probable cause, comparison to the reasonable-suspicion standard is instructive. | 2 | 2 |
Reid v. Georgiagreen2 sentences2015Reasonable suspicion for traffic stops cannot rest solely on “circumstances or factors that do not reliably distinguish between suspect and innocent behaviors ... because they may cast too wide a net and subject all travelers to ‘virtually random seizures.’” State v. Sweeney, 224 Ariz. 107, ¶ 22 , 227 P.3d 868, 874 (App.2010), quoting Reid v. Georgia, 448 U.S. 438, 441 , 100 S.Ct. 2752 , 65 L.Ed.2d 890 (1980) (per curiam). 2015Reasonable suspicion for traffic stops cannot rest solely on “circumstances or factors that do not reliably distinguish between suspect and innocent behaviors ... because they may cast too wide a net and subject all travelers to ‘virtually random seizures.’” State v. Sweeney, 224 Ariz. 107, ¶ 22 , 227 P.3d 868, 874 (App.2010), quoting Reid v. Georgia, 448 U.S. 438, 441 , 100 S.Ct. 2752 , 65 L.Ed.2d 890 (1980) (per curiam). | 2 | 2 |
Kansas v. Glovergreen2 sentences2025“Although a mere ‘hunch’ does not create reasonable suspicion, the level of suspicion the standard requires is considerably less than proof of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for probable cause.” Kansas v. Glover, 589 U.S. 376, 380 (2020) (quoting Prado Navarette v. California, 572 U.S. 393, 397 (2014) (quotation altered)); see also Sokolow, 490 U.S. at 7 . ¶18 Relevant here, the Arizona Legislature codified the reasonable suspicion standard for traffic violations in A.R.S. § 28-1594: “A peace officer or duly authorized agent of a traffic enf 2025“Although a mere ‘hunch’ does not create reasonable suspicion, the level of suspicion the standard requires is considerably less than proof of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for probable cause.” Kansas v. Glover, 589 U.S. 376 , 380 (2020) (quoting Prado Navarette v. California, 572 U.S. 393, 397 (2014) (quotation altered)); see also Sokolow, 490 U.S. at 7 . ¶18 Relevant here, the Arizona Legislature codified the reasonable suspicion standard for traffic violations in A.R.S. § 28-1594: “A peace officer or duly authorized agent of a traffic en | 1 | 2 |
State v. Blackmoregreen1 sentence2024United States v. Sokolow, 490 U.S. 1, 7 (1989). ¶18 “[T]he police officer must be able to point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.” State v. Blackmore, 186 Ariz. 630, 633 (1996) (quoting Terry, 392 U.S. at 21 ). | 1 | 1 |
In Re Ilono H.green1 sentence2013Quoting from Justice Harlan’s concurring opinion in Terry , the Ilono H. court explained: “[I]f the frisk is justified in order to protect the officer during an encounter with a citizen, the officer must first have constitutional grounds to insist on an encounter, to make a forcible stop.” Id. at 476, ¶ 11, 113 P.3d at 699 (emphasis omitted) (quoting Terry, 392 U.S. at 32 , 88 S.Ct. at 1885 (Harlan, J., concurring)). ¶36 The majority rejects Ilono H. and, relying on a ease decided by the Ninth Circuit Court of Appeals, United States v. Orman, 486 F.3d 1170 (9th Cir.2007), justifies its rejecti | 1 | 1 |
State v. Garcia-Garciagreen2 sentences2010Terry, 392 U.S. at 27, 30 , 88 S.Ct. at 1883, 1884-85 ; State v. Garcia Garcia, 169 Ariz. 530, 531-32 , 821 P.2d 191, 192-93 (App.1991). ¶ 18 The reasonable suspicion standard is a lower standard than that required for probable cause to make an arrest and it requires a showing considerably less than a preponderance of the evidence. 2010Terry, 392 U.S. at 27, 30 , 88 S.Ct. at 1883, 1884-85 ; State v. Garcia Garcia, 169 Ariz. 530, 531-32 , 821 P.2d 191, 192-93 (App.1991). ¶ 18 The reasonable suspicion standard is a lower standard than that required for probable cause to make an arrest and it requires a showing considerably less than a preponderance of the evidence. | 1 | 1 |
In Re Roy L.green2 sentences2010United States v. Sokolow, 490 U.S. 1, 7 , 109 S.Ct. 1581, 1585 , 104 L.Ed.2d 1 (1989); Fornof 218 Ariz. at 76, ¶ 5 , 179 P.3d at 956 ; see In re Roy L., 197 Ariz. at 444-45, ¶ 8 , 4 P.3d at 987-88 . 2010United States v. Sokolow, 490 U.S. 1, 7 , 109 S.Ct. 1581, 1585 , 104 L.Ed.2d 1 (1989); Fornof 218 Ariz. at 76, ¶ 5 , 179 P.3d at 956 ; see In re Roy L., 197 Ariz. at 444-45, ¶ 8 , 4 P.3d at 987-88 . | 1 | 1 |
State v. Fornofgreen2 sentences2010United States v. Sokolow, 490 U.S. 1, 7 , 109 S.Ct. 1581, 1585 , 104 L.Ed.2d 1 (1989); Fornof 218 Ariz. at 76, ¶ 5 , 179 P.3d at 956 ; see In re Roy L., 197 Ariz. at 444-45, ¶ 8 , 4 P.3d at 987-88 . 2010United States v. Sokolow, 490 U.S. 1, 7 , 109 S.Ct. 1581, 1585 , 104 L.Ed.2d 1 (1989); Fornof 218 Ariz. at 76, ¶ 5 , 179 P.3d at 956 ; see In re Roy L., 197 Ariz. at 444-45, ¶ 8 , 4 P.3d at 987-88 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Samson v. California
green
2 sentences2016Id. at 853 , 855 n.4, 126 S.Ct. 2193 . ¶ 20 Second, Samson observed that “[i]m-posing a reasonable suspicion requirement ... would give parolees greater opportunity to anticipate searches and conceal criminality.” Id. at 854 , 126 S.Ct, 2193 . 2016Id. at 853 , 855 n.4, 126 S.Ct. 2193 . ¶ 20 Second, Samson observed that “[i]m-posing a reasonable suspicion requirement ... would give parolees greater opportunity to anticipate searches and conceal criminality.” Id. at 854 , 126 S.Ct, 2193 . | 2 | 2015–2016 |
Michigan v. Long
green
2 sentences2018The Court also noted that the reasonable belief standard was the same as the reasonable suspicion standard discussed in Terry v. Ohio, 392 U.S. 1 (1968) and Michigan v. Long, 463 U.S. 1032 (1983). 2018Id. | 1 | 2018–2018 |
United States v. Knights
green
2 sentences2015Instead, Samson directs that a reviewing court must “ ‘examin[e] the totality of the circumstances’ to determine whether [such] a search is reasonable within the meaning of the Fourth Amendment.” 547 U.S. at 848, 126 S.Ct. 2193 (quoting Knights, 534 U.S. at 118 , 122 S.Ct. 587 ). ¶ 18 Samson involved a police officer’s suspicionless search of a parolee’s person based on his status as a parolee. 547 U.S. at 846, 126 S.Ct. 2193 . 2015Instead, Samson directs that a reviewing court must “ ‘examin[e] the totality of the circumstances’ to determine whether [such] a search is reasonable within the meaning of the Fourth Amendment.” 547 U.S. at 848, 126 S.Ct. 2193 (quoting Knights, 534 U.S. at 118 , 122 S.Ct. 587 ). ¶ 18 Samson involved a police officer’s suspicionless search of a parolee’s person based on his status as a parolee. 547 U.S. at 846, 126 S.Ct. 2193 . | 1 | 2015–2015 |
United States v. Dale Washington Orman
green
1 sentence2013Quoting from Justice Harlan’s concurring opinion in Terry , the Ilono H. court explained: “[I]f the frisk is justified in order to protect the officer during an encounter with a citizen, the officer must first have constitutional grounds to insist on an encounter, to make a forcible stop.” Id. at 476, ¶ 11, 113 P.3d at 699 (emphasis omitted) (quoting Terry, 392 U.S. at 32 , 88 S.Ct. at 1885 (Harlan, J., concurring)). ¶36 The majority rejects Ilono H. and, relying on a ease decided by the Ninth Circuit Court of Appeals, United States v. Orman, 486 F.3d 1170 (9th Cir.2007), justifies its rejecti | 1 | 2013–2013 |
Whren v. United States
green
2 sentences2009The trial court here applied a reasonable suspicion standard. ¶ 10 Defendant points to the United States Supreme Court decision in Whren v. United States, 517 U.S. 806, 810 , 116 S.Ct. 1769 , 135 L.Ed.2d 89 (1996), in which the Court stated that “the decision to stop an automobile is reasonable where the police have probable cause to believe that a traffic violation has occurred.” (Emphasis added.) The broader issue in Whren was whether an officer who stops someone based on a traffic violation must also be “motivated to stop the car by a desire to enforce the traffic laws.” Id. at 808 , 116 S. 2009The trial court here applied a reasonable suspicion standard. ¶ 10 Defendant points to the United States Supreme Court decision in Whren v. United States, 517 U.S. 806, 810 , 116 S.Ct. 1769 , 135 L.Ed.2d 89 (1996), in which the Court stated that “the decision to stop an automobile is reasonable where the police have probable cause to believe that a traffic violation has occurred.” (Emphasis added.) The broader issue in Whren was whether an officer who stops someone based on a traffic violation must also be “motivated to stop the car by a desire to enforce the traffic laws.” Id. at 808 , 116 S. | 1 | 2009–2009 |
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.
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.