combination of wholly innocent factors in Maryland

2026We reiterated that “it is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Id. at 512, 970 A.2d at 907 (citation modified).

2022The Fourth Amendment only authorizes a Terry stop when an officer, based upon an objective observation, infers and deduces “the particular individual being stopped is engaged in wrongdoing.” Id. at 460-61, 78 A.3d at 425 (citation omitted). “[I]t is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Crosby, 408 Md. at 512 , 970 A.2d at 907 (cleaned up). 10 The State frames the question before the Court as follows: [T]he question here is not how common it is for any person to flee fro

2009As several courts have observed, “it is ‘impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.’ ” United States v. Wood, 106 F.3d 942, 948 (10th Cir.1997) (quoting Karnes v. Skrutski, 62 F.3d 485, 496 (3d Cir.1995)); Cartnail, 359 Md. at 294 , 753 A.2d at 531 (quoting same language); see also Lilley v. State, 362 Ark. 436 , 208 S.W.3d 785, 791 (2005) (quoting same language).

2005The Court concluded that reasonable suspicion did not exist, noting that “it is ‘impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.’ ” Id. at 294, 753 A.2d 519 (quoting U.S. v. Wood, 106 F.3d 942, 948 (10th Cir.1997)).

2022The Fourth Amendment only authorizes a Terry stop when an officer, based upon an objective observation, infers and deduces “the particular individual being stopped is engaged in wrongdoing.” Id. at 460-61, 78 A.3d at 425 (citation omitted). “[I]t is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Crosby, 408 Md. at 512 , 970 A.2d at 907 (cleaned up). 10 The State frames the question before the Court as follows: [T]he question here is not how common it is for any person to flee fro

2022The Fourth Amendment only authorizes a Terry stop when an officer, based upon an objective observation, infers and deduces “the particular individual being stopped is engaged in wrongdoing.” Id. at 460-61, 78 A.3d at 425 (citation omitted). “[I]t is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Crosby, 408 Md. at 512 , 970 A.2d at 907 (cleaned up). 10 The State frames the question before the Court as follows: [T]he question here is not how common it is for any person to flee fro

2026We concluded that, “although the nature of the totality of the circumstances test makes it possible for individually innocuous factors to add up to reasonable suspicion, it is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Cartnail, 359 Md. at 294 , 753 A.2d at 531 (citation modified).

2026We concluded that, “although the nature of the totality of the circumstances test makes it possible for individually innocuous factors to add up to reasonable suspicion, it is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Cartnail, 359 Md. at 294 , 753 A.2d at 531 (citation modified).

2009As several courts have observed, “it is ‘impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.’ ” United States v. Wood, 106 F.3d 942, 948 (10th Cir.1997) (quoting Karnes v. Skrutski, 62 F.3d 485, 496 (3d Cir.1995)); Cartnail, 359 Md. at 294 , 753 A.2d at 531 (quoting same language); see also Lilley v. State, 362 Ark. 436 , 208 S.W.3d 785, 791 (2005) (quoting same language).

2000Furthermore, “[ajlthough the nature of the totality of the circumstances test makes it possible for individually innocuous factors to add up to reasonable suspicion, it is ‘impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.’ ” United States v. Wood, 106 F.3d 942, 948 (10th Cir.1997)(citing Karnes, 62 F.3d at 496 ).

2026Second, “it is not enough that law enforcement officials can articulate reasons why they stopped [a driver]”; the reasons “together must serve to eliminate a substantial portion of innocent travelers before the requirement of reasonable suspicion will be satisfied.” Ferris, 355 Md. at 387 , 735 A.2d at 507 (citation modified); Cartnail, 359 Md. at 291 , 753 A.2d at 529-30 (citation modified).

2026Second, “it is not enough that law enforcement officials can articulate reasons why they stopped [a driver]”; the reasons “together must serve to eliminate a substantial portion of innocent travelers before the requirement of reasonable suspicion will be satisfied.” Ferris, 355 Md. at 387 , 735 A.2d at 507 (citation modified); Cartnail, 359 Md. at 291 , 753 A.2d at 529-30 (citation modified).

2026First, “it is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Lewis, 398 Md. at 366 , 920 A.2d at 1090 (citation modified).

2026First, “it is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Lewis, 398 Md. at 366 , 920 A.2d at 1090 (citation modified).

2026In Rowe v. State, 363 Md. 424, 441 , 769 A.2d 879, 889 (2001), we concluded that a State trooper’s observation of the defendant’s “momentary crossing of the edge line of the roadway and later touching of that line did not amount to an unsafe lane change or unsafe entry onto the roadway,” conduct which is prohibited by TR § 21-309, and as such could not support a traffic stop.

2026In Rowe v. State, 363 Md. 424, 441 , 769 A.2d 879, 889 (2001), we concluded that a State trooper’s observation of the defendant’s “momentary crossing of the edge line of the roadway and later touching of that line did not amount to an unsafe lane change or unsafe entry onto the roadway,” conduct which is prohibited by TR § 21-309, and as such could not support a traffic stop.

2019To articulate reasonable suspicion, an “officer must explain how the observed conduct, when viewed in the context of all the other circumstances known to the officer, was indicative of criminal activity.” Sizer, 456 - 21 - Md. at 365, 174 A.3d at 334 (citation and internal quotations omitted). “[I]t is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Sellman, 449 Md. at 549 , 144 A.3d at 785 (citation omitted).

2019To articulate reasonable suspicion, an “officer must explain how the observed conduct, when viewed in the context of all the other circumstances known to the officer, was indicative of criminal activity.” Sizer, 456 - 21 - Md. at 365, 174 A.3d at 334 (citation and internal quotations omitted). “[I]t is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Sellman, 449 Md. at 549 , 144 A.3d at 785 (citation omitted).

2019To articulate reasonable suspicion, an “officer must explain how the observed conduct, when viewed in the context of all the other circumstances known to the officer, was indicative of criminal activity.” Sizer, 456 - 21 - Md. at 365, 174 A.3d at 334 (citation and internal quotations omitted). “[I]t is impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.” Sellman, 449 Md. at 549 , 144 A.3d at 785 (citation omitted).

2009As several courts have observed, “it is ‘impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.’ ” United States v. Wood, 106 F.3d 942, 948 (10th Cir.1997) (quoting Karnes v. Skrutski, 62 F.3d 485, 496 (3d Cir.1995)); Cartnail, 359 Md. at 294 , 753 A.2d at 531 (quoting same language); see also Lilley v. State, 362 Ark. 436 , 208 S.W.3d 785, 791 (2005) (quoting same language).

2009As several courts have observed, “it is ‘impossible for a combination of wholly innocent factors to combine into a suspicious conglomeration unless there are concrete reasons for such an interpretation.’ ” United States v. Wood, 106 F.3d 942, 948 (10th Cir.1997) (quoting Karnes v. Skrutski, 62 F.3d 485, 496 (3d Cir.1995)); Cartnail, 359 Md. at 294 , 753 A.2d at 531 (quoting same language); see also Lilley v. State, 362 Ark. 436 , 208 S.W.3d 785, 791 (2005) (quoting same language).