reasonable suspicion requirement (Indiana) · Go Syfert
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reasonable suspicion requirement in Indiana

80 Indiana opinions name it 2 courts 1993–2026 4 in the last five years

The cases below were cited by Indiana 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 (31)

CaseFollowedCited
Lyons v. Stategreen
indctapp · 2000 · cited in 7 Indiana opinions naming this issue, 2002–2017
2 sentences

2017Lyons v. State, 735 N.E.2d 1179, 1183-84 (Ind. Ct. App. 2000), trans. denied.

2015Lyons v. State, 735 N.E.2d 1179, 1183-84 (Ind. Ct. App. 2000), trans. denied; see also Gipson v. State, 459 N.E.2d 366, 368 (Ind. 1984).

77
Finger v. Stategreen
ind · 2003 · cited in 6 Indiana opinions naming this issue, 2016–2023
2 sentences

2023It “entails something more than an inchoate and unparticularized suspicion or hunch but considerably less than proof of wrongdoing by a preponderance of the evidence.” Id. “[A] set of individually innocent facts, when observed in conjunction, can be sufficient to create reasonable suspicion of criminal activity.” Finger v. State, 799 N.E.2d 528, 534 (Ind. 2003).

2017See Finger v. State, 799 N.E.2d 528, 533 (Ind. 2003) (“The reasonable suspicion inquiry is highly fact-sensitive and is reviewed under a sufficiency of the evidence standard.

56
LW v. Stategreen
indctapp · 2010 · cited in 6 Indiana opinions naming this issue, 2010–2016
2 sentences

2016“The reasonable suspicion requirement is met where the facts known to the officer,, together with the reasonable inferences arising from such facts, would cause an ordinarily prudent person to believe criminal activity has occurred or is about to occur.” L.W. v. State, 926 N.E.2d 52, 55 (Ind.Ct.App.2010). [Stops initiated pursuant to Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 [ 20 L.Ed.2d 889 ] (1968) ] are limited in scope and purpose.

2013The reasonable-suspicion requirement is met “where the facts known to the officer, together with the reasonable inferences arising from such facts, would cause an ordinarily prudent person to believe criminal activity has occurred or is about to occur.” L.W. v. State, 926 N.E.2d 52, 55 (Ind.Ct.App.2010), reh’g denied.

46
J.B. v. State of Indianagreen
indctapp · 2015 · cited in 5 Indiana opinions naming this issue, 2016–2016
2 sentences

2016Id. [13] Here, Officer Watson testified that he saw Hancock driving a maroon Kia the day before the arrest.

2016J.B. v. State, 30 N.E.3d 51, 55 (Ind.Ct.App.2015) (citations and quotation marks omitted). [17] Before applying the reasonable suspicion requirement to the facts of this case, we must first address Mullen’s claim that Terry does not apply to private property.

45
Lampkins v. Stategreen
ind · 1997 · cited in 5 Indiana opinions naming this issue, 2000–2013
2 sentences

2013Lampkins v. State, 682 N.E.2d 1268, 1271 (Ind. 1997), modified on reh’g on other grounds, 685 N.E.2d 698 .

2006Lampkins v. State, 682 N.E.2d 1268, 1271 (Ind.1997), modified on reh'g on other grounds, 685 N.E.2d 698 .

45
Gipson v. Stategreen
ind · 1984 · cited in 4 Indiana opinions naming this issue, 2002–2015
2 sentences

2015Lyons v. State, 735 N.E.2d 1179, 1183-84 (Ind. Ct. App. 2000), trans. denied; see also Gipson v. State, 459 N.E.2d 366, 368 (Ind. 1984).

2013Lyons v. State, 735 N.E.2d 1179, 1183-1184 (Ind. Ct. App. 2000), trans. denied; see also Gipson v. State, 459 N.E.2d 366, 368 (Ind. 1984).

44
Teague v. Stategreen
indctapp · 2008 · cited in 4 Indiana opinions naming this issue, 2010–2015
2 sentences

2012“The reasonable suspicion standard is less demanding than probable cause and requires a showing considerably less than a preponderance of the evidence, but it still requires at least a minimal level of objective justification and more than an inchoate and unparticularized suspicion or hunch of criminal activity.” Teague v. State, 891 N.E.2d 1121, 1128 (Ind. Ct. App. 2008).

2010"The reasonable suspicion standard is less demanding than probable cause and requires a showing considerably less than a preponderance of the evidence, but it still requires at least a minimal level of objective justification and more than an inchoate and unparticularized suspicion or hunch of criminal activity." Teague v. State, 891 N.E.2d 1121, 1128 (Ind.Ct.App. 2008).

34
Carter v. Stategreen
indctapp · 1998 · cited in 4 Indiana opinions naming this issue, 2000–2002
2 sentences

2002Carter v. State, 692 N.E.2d 464, 466 (Ind.Ct.App.1997).

2002Carter v. State, 692 N.E.2d 464, 466 (Ind.Ct.App.1997).

34
State v. Atkinsgreen
indctapp · 2005 · cited in 3 Indiana opinions naming this issue, 2009–2016
2 sentences

2009In State v. Atkins, 834 N.E.2d 1028, 1032 (Ind.Ct.App.2005), trans. denied, another panel of this court held: Initially, we note that the reasonable suspicion analysis first articulated in Terry does not apply to this case.

2009In State v. Atkins, 834 N.E.2d 1028, 1032 (Ind.Ct.App.2005), trans. denied, another panel of this court held: Initially, we note that the reasonable suspicion analysis first articulated in Terry does not apply to this case.

33
Francis v. Stategreen
indctapp · 2002 · cited in 4 Indiana opinions naming this issue, 2002–2013
2 sentences

2013Francis v. State, 764 N.E.2d 641, 644 (Ind.Ct.App.2002).

2006Id.

24
Crabtree v. Stategreen
indctapp · 2002 · cited in 3 Indiana opinions naming this issue, 2018–2023
2 sentences

2023The reasonable suspicion requirement is satisfied when “the facts known to the officer, together with the reasonable inferences arising from such facts, would cause an ordinarily prudent person to believe that criminal activity has occurred or is about to occur.” Crabtree v. State, 762 N.E.2d 241, 246 (Ind. Ct. App. 2002).

2023The reasonable suspicion requirement is satisfied when “the facts known to the officer, together with the reasonable inferences arising from such facts, would cause an ordinarily prudent person to believe that criminal activity has occurred or is about to occur.” Crabtree v. State, 762 N.E.2d 241, 246 (Ind. Ct. App. 2002).

23
Moultry v. Stategreen
indctapp · 2004 · cited in 2 Indiana opinions naming this issue, 2012–2015
2 sentences

2015Moultry v. State, 808 N.E.2d 168, 171 (Ind.Ct.App.2004). [14] In this case, Officer Wallace saw J.B. discard what he believed to be a firearm in a yard as J.B. walked along a sidewalk.

2012Moultry v. State, 808 N.E.2d 168, 171 (Ind. Ct. App. 9 2004).

22
State v. DSgreen
fladistctapp · 1996 · cited in 2 Indiana opinions naming this issue, 2007–2007
2 sentences

2007State v. D.S., 685 So.2d 41, 43 (Fla.Ct.App.1996) (holding that school police officers are always subject to the reasonable suspicion standard for school searches "since the school police officer is a school official who is employed by the district School Board") (emphasis in original).

2007State v. D.S., 685 So.2d 41, 43 (Fla.Ct.App.1996) (holding that school police officers are always subject to the reasonable suspicion standard for school searches “since the school police officer is a school official who is employed by the district School Board”) (emphasis in original).

22
United States v. Gregory L. Pricegreen
ca7 · 1999 · cited in 2 Indiana opinions naming this issue, 2000–2000
2 sentences

2000Similarly, the Seventh Circuit, in United States v. Price, 184 F.3d 637, 642 (7th Cir.1999) found that an anonymous tip that an amount of cocaine would be in a particular car, a description of the defendant and those traveling with him, where the trip originated, and where it would conclude, provided reasonable suspicion for a Terry stop.

2000Similarly, the Seventh Circuit, in United States v. Price, 184 F.3d 637, 642 (7th Cir.1999) found that an anonymous tip that an amount of cocaine would be in a particular car, a description of the defendant and those traveling with him, where the trip originated, and where it would conclude, provided reasonable suspicion for a Terry stop.

22
United States v. Sanchez-Penagreen
ca5 · 2003 · cited in 1 Indiana opinions naming this issue, 2026–2026
1 sentence

2026Ct. App. 2004)). [14] The Nevada court also recognized that many jurisdictions have concluded that the reasonable suspicion standard is satisfied where the motorist is driving well below the speed limit and is engaged in another unusual driving behavior 2 indicative of intoxication, such as swerving in the travel lane, driving on the 3 4 5 shoulder of the road, straddling the lane, crossing the center line, or weaving 2 Wells v. State, 772 N.E.2d 487, 490 (Ind. Ct. App. 2002). 3 U.S. v. Sanchez-Pena, 336 F.3d 431, 437 (5th Cir. 2003). 4 U.S. v. Botero-Ospina, 71 F.3d 783, 788 (10th Cir. 1995).

11
United States v. Carlos Botero-Ospinagreen
ca10 · 1995 · cited in 1 Indiana opinions naming this issue, 2026–2026
1 sentence

2026Ct. App. 2004)). [14] The Nevada court also recognized that many jurisdictions have concluded that the reasonable suspicion standard is satisfied where the motorist is driving well below the speed limit and is engaged in another unusual driving behavior 2 indicative of intoxication, such as swerving in the travel lane, driving on the 3 4 5 shoulder of the road, straddling the lane, crossing the center line, or weaving 2 Wells v. State, 772 N.E.2d 487, 490 (Ind. Ct. App. 2002). 3 U.S. v. Sanchez-Pena, 336 F.3d 431, 437 (5th Cir. 2003). 4 U.S. v. Botero-Ospina, 71 F.3d 783, 788 (10th Cir. 1995).

11
Wells v. Stategreen
indctapp · 2002 · cited in 1 Indiana opinions naming this issue, 2026–2026
1 sentence

2026Ct. App. 2004)). [14] The Nevada court also recognized that many jurisdictions have concluded that the reasonable suspicion standard is satisfied where the motorist is driving well below the speed limit and is engaged in another unusual driving behavior 2 indicative of intoxication, such as swerving in the travel lane, driving on the 3 4 5 shoulder of the road, straddling the lane, crossing the center line, or weaving 2 Wells v. State, 772 N.E.2d 487, 490 (Ind. Ct. App. 2002). 3 U.S. v. Sanchez-Pena, 336 F.3d 431, 437 (5th Cir. 2003). 4 U.S. v. Botero-Ospina, 71 F.3d 783, 788 (10th Cir. 1995).

11
United States v. Darrell Paul Bertrand, United States of America v. John Owen Rapaegreen
ca9 · 1991 · cited in 1 Indiana opinions naming this issue, 2026–2026
1 sentence

2026Ct. App. 2004)). [14] The Nevada court also recognized that many jurisdictions have concluded that the reasonable suspicion standard is satisfied where the motorist is driving well below the speed limit and is engaged in another unusual driving behavior 2 indicative of intoxication, such as swerving in the travel lane, driving on the 3 4 5 shoulder of the road, straddling the lane, crossing the center line, or weaving 2 Wells v. State, 772 N.E.2d 487, 490 (Ind. Ct. App. 2002). 3 U.S. v. Sanchez-Pena, 336 F.3d 431, 437 (5th Cir. 2003). 4 U.S. v. Botero-Ospina, 71 F.3d 783, 788 (10th Cir. 1995).

11
Kevin M. Clark v. State of Indianagreen
ind · 2013 · cited in 1 Indiana opinions naming this issue, 2024–2024
1 sentence

2024Clark v. State, 994 N.E.2d 252, 261 (Ind. 2013).

11
Erving Sanders v. State of Indianagreen
ind · 2013 · cited in 1 Indiana opinions naming this issue, 2019–2019
11
Campos v. Stategreen
ind · 2008 · cited in 1 Indiana opinions naming this issue, 2019–2019
11
State v. Richardsongreen
ind · 2010 · cited in 1 Indiana opinions naming this issue, 2016–2016
11
Barrett v. Stategreen
indctapp · 2005 · cited in 1 Indiana opinions naming this issue, 2014–2014
11
Bogetti v. Stategreen
indctapp · 2000 · cited in 1 Indiana opinions naming this issue, 2012–2012
11
Ertel v. Stategreen
indctapp · 2010 · cited in 1 Indiana opinions naming this issue, 2012–2012
11
Baldwin v. Reagangreen
ind · 1999 · cited in 1 Indiana opinions naming this issue, 2010–2010
11
Membres v. Stategreen
ind · 2008 · cited in 1 Indiana opinions naming this issue, 2009–2009
11
Richards v. Wisconsingreen
scotus · 1997 · cited in 1 Indiana opinions naming this issue, 2008–2008
11
Turner v. Stategreen
indctapp · 2007 · cited in 1 Indiana opinions naming this issue, 2008–2008
11
Cardwell v. Stategreen
indctapp · 1996 · cited in 1 Indiana opinions naming this issue, 2007–2007
11
State v. Gladneygreen
indctapp · 2003 · cited in 1 Indiana opinions naming this issue, 2006–2006
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (29)

CaseCitedYears
United States v. Arvizu green
scotus · 2002
2 sentences

2013Id.

2010Id.

62005–2013
Illinois v. Wardlow green
scotus · 2000
2 sentences

2016The Atkins court observed that “the Terry stop and frisk rule applies to cases, involving a brief encounter between a citizen and a police officer on a public street.” Id, (citing Illinois v. Wardlow, 528 U.S., 119, 123 , 120 S.Ct. 673 , 145 L.Ed.2d 570 (2000)). 'The Atkins court concluded that the reasonable suspicion analysis articulated in Terry did not apply because the encounter between Atkins and the police did not occur on a public street but on Atkins’s “own property [the property on the side of his house], in a place where he had a right to be.

2016The Atkins court observed that “the Terry stop and frisk rule applies to cases, involving a brief encounter between a citizen and a police officer on a public street.” Id, (citing Illinois v. Wardlow, 528 U.S., 119, 123 , 120 S.Ct. 673 , 145 L.Ed.2d 570 (2000)). 'The Atkins court concluded that the reasonable suspicion analysis articulated in Terry did not apply because the encounter between Atkins and the police did not occur on a public street but on Atkins’s “own property [the property on the side of his house], in a place where he had a right to be.

52005–2016
Lampkins v. State green
ind · 1997
2 sentences

2013Lampkins v. State, 682 N.E.2d 1268, 1271 (Ind. 1997), modified on reh’g on other grounds, 685 N.E.2d 698 .

2006Lampkins v. State, 682 N.E.2d 1268, 1271 (Ind.1997), modified on reh'g on other grounds, 685 N.E.2d 698 .

52000–2013
Terry v. Ohio green
scotus · 1968
2 sentences

2016“The reasonable suspicion requirement is met where the facts known to the officer,, together with the reasonable inferences arising from such facts, would cause an ordinarily prudent person to believe criminal activity has occurred or is about to occur.” L.W. v. State, 926 N.E.2d 52, 55 (Ind.Ct.App.2010). [Stops initiated pursuant to Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 [ 20 L.Ed.2d 889 ] (1968) ] are limited in scope and purpose.

2016“The reasonable suspicion requirement is met where the facts known to the officer,, together with the reasonable inferences arising from such facts, would cause an ordinarily prudent person to believe criminal activity has occurred or is about to occur.” L.W. v. State, 926 N.E.2d 52, 55 (Ind.Ct.App.2010). [Stops initiated pursuant to Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 [ 20 L.Ed.2d 889 ] (1968) ] are limited in scope and purpose.

42005–2016
United States v. Sokolow green
scotus · 1989
2 sentences

2019We often call these encounters Terry Stops, where an officer may "stop and briefly detain a person for investigative purposes if the officer has a reasonable suspicion supported by articulable facts that criminal activity 'may be afoot.' " Id. (quoting United States v. Sokolow , 490 U.S. 1 , 7, 109 S.Ct. 1581 , 104 L.Ed.2d 1 (1989) ).

2012The Court noted that “innocent behavior will frequently provide the basis for a showing of probable cause,” that “[i]n making a determination of probable cause the relevant inquiry is not whether particular conduct is ‘innocent’ or ‘guilty,’ but the degree of suspicion that attaches to particular types of noncriminal acts,” and that this “principle applies equally well to the reasonable suspicion inquiry.” Id. at 10 , 109 S. Ct. at 1587 (quoting Illinois v. Gates, 462 U.S. 213 , 243-244 n.13, 103 S. Ct. 2317 , 2335 n.13 (1983), reh’g denied).

22012–2019
Illinois v. Gates green
scotus · 1983
2 sentences

2012The Court noted that “innocent behavior will frequently provide the basis for a showing of probable cause,” that “[i]n making a determination of probable cause the relevant inquiry is not whether particular conduct is ‘innocent’ or ‘guilty,’ but the degree of suspicion that attaches to particular types of noncriminal acts,” and that this “principle applies equally well to the reasonable suspicion inquiry.” Id. at 10 , 109 S. Ct. at 1587 (quoting Illinois v. Gates, 462 U.S. 213 , 243-244 n.13, 103 S. Ct. 2317 , 2335 n.13 (1983), reh’g denied).

2012The Court noted that “innocent behavior will frequently provide the basis for a showing of probable cause,” that “[i]n making a determination of probable cause the relevant inquiry is not whether particular conduct is ‘innocent’ or ‘guilty,’ but the degree of suspicion that attaches to particular types of noncriminal acts,” and that this “principle applies equally well to the reasonable suspicion inquiry.” Id. at 10 , 109 S. Ct. at 1587 (quoting Illinois v. Gates, 462 U.S. 213 , 243-244 n.13, 103 S. Ct. 2317 , 2335 n.13 (1983), reh’g denied).

22012–2019
State v. Renzulli green
ind · 2011
2 sentences

2018Likewise, "reasonable suspicion does not rise to the level of probable cause." State v. Renzulli , 958 N.E.2d 1143 , 1146 (Ind. 2011).

2012Using an anonymous-tip case from the United States Supreme Court, Alabama v. White, 496 U.S. 325 (1990), our Supreme Court concluded that in White, “the factors upholding the anonymous tip were the officers’ observations that validated the information received, substantiating the reasonable suspicion requirement.” Renzulli, 958 N.E.2d at 1147 .

22012–2018
Washburn v. State green
indctapp · 2007
2 sentences

2010Id.

2008Washburn v. State, 868 N.E.2d 594 (Ind.Ct.App.2007), trans. denied; see also Turner v. State, 878 N.E.2d 286 .

22008–2010
Turner v. State green
indctapp · 2006
2 sentences

2007Id.

2007Id.

22007–2007
State v. Rincon green
nev · 2006
1 sentence

2026However, the Supreme Court of Nevada disagreed and held that, “absent evidence of a traffic violation, there must be additional indicia of erratic driving or unusual behavior before a reasonable suspicion arises that a motorist who is driving slowly is intoxicated.” Id. at 237 .

12026–2026
Prado Navarette v. California green
scotus · 2014
2 sentences

2024Paul, 189 N.E.3d at 1154. [18] This Court has explained the reasonable suspicion standard as follows: “‘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.’” Glover, 140 S. Ct. [1183,] 1187 (quoting Navarette v. California, 572 U.S. 393, 397 , 134 S. Ct. 1683 , 188 L.Ed.2d 680 (2014)). . . .

2024Paul, 189 N.E.3d at 1154. [18] This Court has explained the reasonable suspicion standard as follows: “‘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.’” Glover, 140 S. Ct. [1183,] 1187 (quoting Navarette v. California, 572 U.S. 393, 397 , 134 S. Ct. 1683 , 188 L.Ed.2d 680 (2014)). . . .

12024–2024
United States v. Sean Sowards green
ca4 · 2012
12019–2019
Meredith v. State green
ind · 2009
12019–2019
Joanna S. Robinson v. State of Indiana green
ind · 2014
12019–2019
Polson v. State green
indctapp · 2015
12019–2019
Gregory Johnson v. State of Indiana green
indctapp · 2013
12019–2019
Illinois v. Caballes green
scotus · 2005
12016–2016
State v. Bulington green
ind · 2004
12016–2016
Patrick Austin v. State of Indiana green
ind · 2013
12016–2016
Rodriguez v. United States green
scotus · 2015
12016–2016
Sampson v. United States green
scotus · 2006
12015–2015
Alabama v. White green
scotus · 1990
12012–2012
Kellems v. State green
ind · 2006
12011–2011
State v. Hawkins green
indctapp · 2002
12006–2006
State v. Glass green
indctapp · 2002
12003–2003
Tumblin v. State green
indctapp · 1996
11996–1996
Luster v. State green
indctapp · 1991
11993–1993
Eule FORD, Appellant, v. Leatrice J. DOWD; Alvin J. Wilson; City of Pagedale, Missouri, Appellee green
ca8 · 1991
11993–1993
United States v. Montoya De Hernandez green
scotus · 1985
11993–1993

Statutes the citing opinions construe

IN § Ind. Code § 35-48-4-1 (11) IN § Ind. Code § 35-48-4-6 (10) IN § Ind. Code § 35-48-4-11 (7) IN § Ind. Code § 35-47-2-1 (6) IN § Ind. Code § 35-47-4-5 (5) IN § Ind. Code § 35-38-4-2 (4) IN § Ind. Code § 35-48-4-13 (4) IN § Ind. Code § 35-48-4-7 (3) IN § Ind. Code § 35-48-4-8.3 (3) IN § Ind. Code § 35-50-2-8 (3) IN § Ind. Code § 9-30-5-1 (3) IN § Ind. Code § 9-30-5-2 (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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