reasonable suspicion standard in Minnesota

2026“The reasonable suspicion standard is not high,” but it requires more than an unarticulated “hunch.” State v. Timberlake, 744 N.W.2d 390, 393 (Minn. 2008) (quotations omitted).

2026The reasonable-suspicion standard is “not high” but it requires police “to articulate more than an inchoate and unparticularized suspicion or hunch of criminal activity.” State v. Timberlake, 744 N.W.2d 390, 393 (Minn. 2008) (quotations omitted); see also Diede, 795 N.W.2d at 843 (“A hunch, without additional objectively articulable facts, cannot provide the basis for an investigatory stop.” (quotation omitted)).

2026The reasonable-suspicion standard is “not high” but it requires police “to articulate more than an inchoate and unparticularized suspicion or hunch of criminal activity.” State v. Timberlake, 744 N.W.2d 390, 393 (Minn. 2008) (quotations omitted); see also Diede, 795 N.W.2d at 843 (“A hunch, without additional objectively articulable facts, cannot provide the basis for an investigatory stop.” (quotation omitted)).

2026See Diede, 795 N.W.2d at 842-43 (explaining that reasonable suspicion must be “based on specific, articulable facts” that allow the officer “to articulate at the omnibus hearing that he or she had a particularized and objective basis for suspecting the seized person of criminal activity”); see also Timberlake, 744 N.W.2d at 393 (stating that, under the reasonable-suspicion standard, the officer must articulate a “particularized and objective basis for suspecting the particular person stopped of criminal activity”).

2016The reasonable-suspicion standard “takes into account the totality of the circumstances,” i.e., “the whole picture.” Navarette v. California, 134 S. Ct. 1683, 1687 (2014) (quotation omitted); see also Davis, 732 N.W.2d at 182 .

2016We reiterate that the reasonable-suspicion standard requires only a minimal showing of “something that objectively supports the suspicion at issue.” Davis, 732 N.W.2d at 182 (quotation omitted).

2026Juncewski emphasized that the officers relied on “specific and articulable facts” to support their belief that the driver was impaired and expressly tied the standard to State v. Cavegn, 294 N.W.2d 717 (Minn. 1980), and Marben v. Department of Public Safety, 294 N.W.2d 697 (Minn. 1980), both of which applied the traditional reasonable-suspicion standard from Terry v. Ohio, 392 U.S. 1 (1968).

2026Noting that “it is an open question whether this court must disregard an officer’s subjective belief that no crime has occurred,” the supreme court discussed the general rationale for rejecting consideration of an officer’s subjective beliefs: 21 The rationale for excluding evidence of subjective beliefs from the reasonable-suspicion analysis is not because they are irrelevant, but because “[i]f subjective good faith alone were the test, the protections of the Fourth Amendment would evaporate, and the people would be ‘secure in their persons, houses, papers, and effects,’ only in the discretio

2024The reasonable suspicion standard is “not high.” State v. Bourke, 718 N.W.2d 922, 927 (Minn. 2006) (quotation omitted).

2016The reasonable suspicion standard is “not high.” State v. Bourke, 718 N.W.2d 922, 927 (Minn. 2006) (quotation omitted).

2016“The information necessary to support an investigative stop need not be based on the officer’s personal observations.” In re Welfare of G.M., 560 N.W.2d 687, 691 (Minn. 1997).

2014Reasonable, ar-ticulable suspicion exists “when an officer observes unusual conduct that leads the officer to reasonably conclude in light of his or her experience that criminal activity may be afoot.” In re Welfare of G.M., 560 N.W.2d 687, 691 (Minn.1997); see also State v. Timberlake, 744 N.W.2d 390, 393 (Minn.2008) (stating that the reasonable-suspicion standard is not high, but that the suspicion must be based on more than a mere hunch of criminal activity).

2016“The reasonable-suspicion standard is ‘not high.’” Id. (quoting State v. Timberlake, 744 N.W.2d 390, 393 (Minn.2008)). “[A] trained police officer is entitled to draw inferences on the basis of ‘all of the circumstances ... inferences and deductions that might well elude an untrained person.’” State v. Johnson, 444 N.W.2d 824, 826 (Minn.1989) (quoting United States v. Cortez, 449 U.S. 411, 418 , 101 S.Ct. 690 , 66 L.Ed.2d 621 (1981)).

2016“The reasonable-suspicion standard is ‘not high.’” Id. (quoting State v. Timberlake, 744 N.W.2d 390, 393 (Minn.2008)). “[A] trained police officer is entitled to draw inferences on the basis of ‘all of the circumstances ... inferences and deductions that might well elude an untrained person.’” State v. Johnson, 444 N.W.2d 824, 826 (Minn.1989) (quoting United States v. Cortez, 449 U.S. 411, 418 , 101 S.Ct. 690 , 66 L.Ed.2d 621 (1981)).

2026In determining whether reasonable suspicion exists, courts “consider the totality of the circumstances and acknowledge that trained law enforcement officers are permitted to make inferences and deductions that would be beyond the competence of an untrained person.” State v. Richardson, 622 N.W.2d 823, 825 (Minn. 2001).

2025In determining whether reasonable suspicion exists, courts “consider the totality of the circumstances and acknowledge that trained law enforcement officers are permitted to make inferences and deductions that would be beyond the competence of an untrained person.” State v. Richardson, 622 N.W.2d 823, 825 (Minn. 2001).

2026See id. (“Presence in a known drug house is a relevant, but not conclusive, factor” in reasonable-suspicion analysis); State v. Lemert, 843 N.W.2d 227, 232 (Minn. 2014) (concluding officer’s knowledge of defendant’s ties to drug-trafficking activities provided reasonable suspicion that defendant was armed and dangerous).

2026See State v. Heaton, 812 N.W.2d 904, 910 (Minn. App. 2012) (considering appellant’s criminal history and change in supervisory status as two factors among others in a reasonable suspicion analysis), rev. denied (July 17, 2012); State v. Lugo, 887 N.W.2d 476, 487 (Minn. 2016) (“Arrests not resulting in conviction may be considered when the arrest was for an offense of the same general nature.”); see also State v. Lieberg, 553 N.W.2d 51, 56 (Minn. App. 1996) (concluding that “the trial court properly considered [Lieberg’s criminal history] as one factor in the totality of relevant circumstances”

2024“The reasonable-suspicion standard is not high.” State v. Morse, 878 N.W.2d 499, 502 (Minn. 2016) (citation omitted) (internal quotation marks omitted).

2016“The reasonable-suspicion standard is not high.” State v. Morse, 878 N.W.2d 499, 502 (Minn. 2016) (quoting State v. Diede, 795 N.W.2d 836, 842-43 (Minn. 2011)) (internal citation and quotation marks omitted).

2015State v. Timberlake, 744 N.W.2d 390, 393 (Minn. 2008). “[T]he police must only show that the stop was not the product of mere whim, caprice or idle curiosity, but was based upon specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.” State v. Anderson, 683 N.W.2d 818, 823 (Minn. 2004) (quotations omitted). 3 “The information necessary to support an investigative stop need not be based on the officer’s personal observations, rather, the police can base an investigative stop on an informant’s tip if it has sufficient ind

2015While the reasonable suspicion standard is not high, an officer’s suspicion must not be the product of “mere whim, caprice or idle curiosity.” State v. Anderson, 683 N.W.2d 818, 823 (Minn. 2004).

2026See State v. Heaton, 812 N.W.2d 904, 910 (Minn. App. 2012) (considering appellant’s criminal history and change in supervisory status as two factors among others in a reasonable suspicion analysis), rev. denied (July 17, 2012); State v. Lugo, 887 N.W.2d 476, 487 (Minn. 2016) (“Arrests not resulting in conviction may be considered when the arrest was for an offense of the same general nature.”); see also State v. Lieberg, 553 N.W.2d 51, 56 (Minn. App. 1996) (concluding that “the trial court properly considered [Lieberg’s criminal history] as one factor in the totality of relevant circumstances”

2016Use of the reasonable suspicion standard is consistent with this court’s goals of preserving the “law enforcement utility” of narcotics-detection dogs and ensuring that the police are not allowed to use narcotics-detection dogs “at random and without reason.” Id. at 181-82 (quoting Carter, 697 N.W.2d at 211 ).

2026See id. (“Presence in a known drug house is a relevant, but not conclusive, factor” in reasonable-suspicion analysis); State v. Lemert, 843 N.W.2d 227, 232 (Minn. 2014) (concluding officer’s knowledge of defendant’s ties to drug-trafficking activities provided reasonable suspicion that defendant was armed and dangerous).

2015An officer “must articulate a ‘particularized and objective basis for suspecting 5 the particular person stopped of criminal activity.’” Id. (quoting United States v. Cortez, 449 U.S. 411 , 417–18, 101 S. Ct. 690, 695 (1981)). “[Appellate courts] consider the totality of the circumstances when determining whether reasonable, articulable suspicion exists.” Flowers, 734 N.W.2d at 251 . “[Appellate courts] evaluate whether a reasonable, articulable suspicion exists from the perspective of a trained police officer, who may make ‘inferences and deductions that might well elude an untrained person.’

2016Alabama v. White, 496 U.S. 325, 328-29 , 110 S. Ct. 2412, 2415 (1990).

2016Alabama v. White, 496 U.S. 325, 328-29 , 110 S. Ct. 2412, 2415 (1990).

2016If the officers had nothing more than the information provided by the informant before they arrived at the gas station, the tip might have been insufficient to satisfy the reasonable-suspicion standard, for essentially the same reasons as in J.L., in which the Court stated that an informant’s tip needs to “identify a determinate person” and “be reliable in its assertion of illegality.” 529 U.S. at 272 , 120 S. Ct. at 1379 .

2016If the officers had nothing more than the information provided by the informant before they arrived at the gas station, the tip might have been insufficient to satisfy the reasonable-suspicion standard, for essentially the same reasons as in J.L., in which the Court stated that an informant’s tip needs to “identify a determinate person” and “be reliable in its assertion of illegality.” 529 U.S. at 272 , 120 S. Ct. at 1379 .

2016In determining whether the reasonable-suspicion standard has been met, courts “should consider the totality of the circumstances and should remember that trained law-enforcement officers are permitted to make inferences and deductions that might well elude an untrained person.” State v. Kvam, 336 N.W.2d 525, 528 (Minn. 1983) (quotation omitted).

2016In determining whether the reasonable-suspicion standard has been met, courts “should consider the totality of the circumstances and should remember that trained law-enforcement officers are permitted to make inferences and deductions that might well elude an untrained person.” State v. Kvam, 336 N.W.2d 525, 528 (Minn. 1983) (quotation omitted).

2016The reasonable-suspicion standard “takes into account the totality of the circumstances,” i.e., “the whole picture.” Navarette v. California, 134 S. Ct. 1683, 1687 (2014) (quotation omitted); see also Davis, 732 N.W.2d at 182 .

2016The reasonable-suspicion standard “takes into account the totality of the circumstances,” i.e., “the whole picture.” Navarette v. California, 134 S. Ct. 1683, 1687 (2014) (quotation omitted).

2015“The reasonable-suspicion standard is not high,” Diede, 795 N.W.2d at 843 (quotation omitted), and is “less demanding than probable cause or a preponderance of the evidence,” Smith, 814 N.W.2d at 352 (quotation omitted).

2013“The reasonable-suspicion standard is not high,” Diede, 795 N.W.2d at 843 (quotation omitted), and “is less de manding than probable cause or a preponderance of the evidence,” State v. Smith, 814 N.W.2d 346, 352 (Minn.2012) (quotation omitted).

2007See, e.g., Ortiz, 600 N.W.2d at 817 (concluding that an individual has a "legitimate expectation of some measure of privacy” in an apartment hallway, and therefore a dog sniff outside an apartment door requires reasonable suspicion rather than probable cause); Dunn, 563 N.Y.S.2d 388 , 564 N.E.2d at 1058 (discussing a dog sniff at the defendant’s apartment door and concluding that "[g]iven the uniquely discriminate and nonintrusive nature of [a dog sniff as] an investigative device, as well as its significant utility to law enforcement authorities,” a dog sniff "may be used without a warrant or

2007See, e.g., Ortiz, 600 N.W.2d at 817 (concluding that an individual has a "legitimate expectation of some measure of privacy” in an apartment hallway, and therefore a dog sniff outside an apartment door requires reasonable suspicion rather than probable cause); Dunn, 563 N.Y.S.2d 388 , 564 N.E.2d at 1058 (discussing a dog sniff at the defendant’s apartment door and concluding that "[g]iven the uniquely discriminate and nonintrusive nature of [a dog sniff as] an investigative device, as well as its significant utility to law enforcement authorities,” a dog sniff "may be used without a warrant or

2026Juncewski emphasized that the officers relied on “specific and articulable facts” to support their belief that the driver was impaired and expressly tied the standard to State v. Cavegn, 294 N.W.2d 717 (Minn. 1980), and Marben v. Department of Public Safety, 294 N.W.2d 697 (Minn. 1980), both of which applied the traditional reasonable-suspicion standard from Terry v. Ohio, 392 U.S. 1 (1968).

2026Juncewski, 308 N.W.2d at 321 (citing Cavegn, 294 N.W.2d at 721–22; Marben, 294 N.W.2d at 699–700).

2026The rationale for excluding evidence of subjective beliefs from the reasonable-suspicion analysis is not because they are irrelevant, but because “[i]f subjective good faith alone were the test, the protections of the Fourth Amendment would evaporate, and the people would be ‘secure in their persons, houses, papers, and effects,’ only in the discretion of the police.” State v. Britton, 604 N.W.2d 84 , 15 here, because the Commissioner agreed at oral argument that the officers’ statements were relevant to the reasonable suspicion assessment to the extent that such statements shed light on what

2026Noting that “it is an open question whether this court must disregard an officer’s subjective belief that no crime has occurred,” the supreme court discussed the general rationale for rejecting consideration of an officer’s subjective beliefs: 21 The rationale for excluding evidence of subjective beliefs from the reasonable-suspicion analysis is not because they are irrelevant, but because “[i]f subjective good faith alone were the test, the protections of the Fourth Amendment would evaporate, and the people would be ‘secure in their persons, houses, papers, and effects,’ only in the discretio

2016The reasonable-suspicion standard is not high, Diede, 795 N.W.2d at 843 , and “an actual violation is not necessary.” State v. Haataja, 611 N.W.2d 353, 354 (Minn. App. 2000) (quotation omitted), review denied (Minn. July 25, 2000). “[An] officer must be able to articulate at [an] omnibus hearing that he or she had a particularized and objective basis for suspecting the seized person of criminal activity.” State v. Cripps, 533 N.W.2d 388, 391 (Minn. 1995).

2016“The reasonable-suspicion standard is ‘not high.’” Id. (quoting State v. Timberlake, 744 N.W.2d 390, 393 (Minn.2008)). “[A] trained police officer is entitled to draw inferences on the basis of ‘all of the circumstances ... inferences and deductions that might well elude an untrained person.’” State v. Johnson, 444 N.W.2d 824, 826 (Minn.1989) (quoting United States v. Cortez, 449 U.S. 411, 418 , 101 S.Ct. 690 , 66 L.Ed.2d 621 (1981)).

2016“The police must only show that the stop was not the product of mere whim, caprice or idle curiosity, but was based upon ‘specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.’” State v. Pike, 551 N.W.2d 919 , 921–22 (Minn. 1996) (quoting Terry v. Ohio, 392 U.S. 1, 21 , 88 S. Ct. 1868, 1880 (1968)).

2016“The police must only show that the stop was not the product of mere whim, caprice or idle curiosity, but was based upon ‘specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.’” State v. Pike, 551 N.W.2d 919, 921-22 (Minn. 1996) (quoting Terry v. Ohio, 392 U.S. 1, 21 , 88 S. Ct. 1868, 1880 (1968)).

2026See State v. Heaton, 812 N.W.2d 904, 910 (Minn. App. 2012) (considering appellant’s criminal history and change in supervisory status as two factors among others in a reasonable suspicion analysis), rev. denied (July 17, 2012); State v. Lugo, 887 N.W.2d 476, 487 (Minn. 2016) (“Arrests not resulting in conviction may be considered when the arrest was for an offense of the same general nature.”); see also State v. Lieberg, 553 N.W.2d 51, 56 (Minn. App. 1996) (concluding that “the trial court properly considered [Lieberg’s criminal history] as one factor in the totality of relevant circumstances”

2026See State v. Heaton, 812 N.W.2d 904, 910 (Minn. App. 2012) (considering appellant’s criminal history and change in supervisory status as two factors among others in a reasonable suspicion analysis), rev. denied (July 17, 2012); State v. Lugo, 887 N.W.2d 476, 487 (Minn. 2016) (“Arrests not resulting in conviction may be considered when the arrest was for an offense of the same general nature.”); see also State v. Lieberg, 553 N.W.2d 51, 56 (Minn. App. 1996) (concluding that “the trial court properly considered [Lieberg’s criminal history] as one factor in the totality of relevant circumstances”