demanding standard in Maryland

2026“Reasonable suspicion is a less demanding standard than probable cause not only in the sense that reasonable suspicion can be established with information that is different in quantity or content than that required to establish probable cause, but also in the sense that reasonable suspicion can arise from information that is less reliable than that required to show probable cause.” Alabama v. White, 496 U.S. 325, 330 (1990).

2022We have recognized, in line with United States Supreme Court precedent, that: Reasonable suspicion is a less demanding standard than probable cause not only in the sense that reasonable suspicion can be established with information that is different in quantity or content than that required to establish probable cause, but also in the sense that reasonable suspicion can arise from information that is less reliable than that required to show probable cause[.] Cartnail v. State, 359 Md. 272, 287 , 753 A.2d 519, 527 (2000) (quoting Alabama v. White, 496 U.S. 325, 330 , 110 S. Ct. 2412, 2416 (1990

2013In analyzing the question before us, we bear in mind that reasonable suspicion “does not deal with hard certainties, but with probabilities,” Sokolow, 490 U.S. at 8 , 109 S.Ct. 1581 (quoting Cortez, 449 U.S. at 418 , 101 S.Ct. 690 ), and that “Reasonable suspicion is a less demanding standard than probable cause,” White, 496 U.S. at 330 , 110 S.Ct. 2412 .

2013In analyzing the question before us, we bear in mind that reasonable suspicion “does not deal with hard certainties, but with probabilities,” Sokolow, 490 U.S. at 8 , 109 S.Ct. 1581 (quoting Cortez, 449 U.S. at 418 , 101 S.Ct. 690 ), and that “Reasonable suspicion is a less demanding standard than probable cause,” White, 496 U.S. at 330 , 110 S.Ct. 2412 .

2024See generally Pearson, 555 U.S. 223 , 129 S. Ct. 808 ; Mullenix, 577 U.S. 7 , 136 S. Ct. 305 ; see also D.C. v. Wesby, 583 U.S. 48, 63 , 138 S. Ct. 577, 589 (2018) (“This demanding standard protects all but the plainly incompetent or those who knowingly violate the law.” (quotation marks and citations omitted)).

2024See generally Pearson, 555 U.S. 223 , 129 S. Ct. 808 ; Mullenix, 577 U.S. 7 , 136 S. Ct. 305 ; see also D.C. v. Wesby, 583 U.S. 48, 63 , 138 S. Ct. 577, 589 (2018) (“This demanding standard protects all but the plainly incompetent or those who knowingly violate the law.” (quotation marks and citations omitted)).

2024See generally Pearson, 555 U.S. 223 , 129 S. Ct. 808 ; Mullenix, 577 U.S. 7 , 136 S. Ct. 305 ; see also D.C. v. Wesby, 583 U.S. 48, 63 , 138 S. Ct. 577, 589 (2018) (“This demanding standard protects all but the plainly incompetent or those who knowingly violate the law.” (quotation marks and citations omitted)).

2024See generally Pearson, 555 U.S. 223 , 129 S. Ct. 808 ; Mullenix, 577 U.S. 7 , 136 S. Ct. 305 ; see also D.C. v. Wesby, 583 U.S. 48, 63 , 138 S. Ct. 577, 589 (2018) (“This demanding standard protects all but the plainly incompetent or those who knowingly violate the law.” (quotation marks and citations omitted)).

2024See generally Pearson, 555 U.S. 223 , 129 S. Ct. 808 ; Mullenix, 577 U.S. 7 , 136 S. Ct. 305 ; see also D.C. v. Wesby, 583 U.S. 48, 63 , 138 S. Ct. 577, 589 (2018) (“This demanding standard protects all but the plainly incompetent or those who knowingly violate the law.” (quotation marks and citations omitted)).

2024See generally Pearson, 555 U.S. 223 , 129 S. Ct. 808 ; Mullenix, 577 U.S. 7 , 136 S. Ct. 305 ; see also D.C. v. Wesby, 583 U.S. 48, 63 , 138 S. Ct. 577, 589 (2018) (“This demanding standard protects all but the plainly incompetent or those who knowingly violate the law.” (quotation marks and citations omitted)).

2024Reasonable suspicion “is not a demanding standard, but it does require more than an ‘unparticularized suspicion or hunch.’” Holt v. State, 435 Md. 443, 448 (2013) (quoting Terry v. Ohio, 392 U.S. 1 , 30–31 (1968)).

2024Reasonable suspicion “is not a demanding standard, but it does require more than an ‘unparticularized suspicion or hunch.’” Holt v. State, 435 Md. 443, 448 (2013) (quoting Terry v. Ohio, 392 U.S. 1 , 30–31 (1968)).

2003What is clear, however, is that although it is “a less demanding standard than probable cause,” Id. (quoting Illinois v. Wardlow, 528 U.S. 119, 123 , 120 S.Ct. 673, 675-76 , 145 L.Ed.2d 570, 576 (2000)); see also David S., 367 Md. at 532 , 789 A.2d at 612 (reasonable suspicion is “a common sense, nontechnical conception that considers factual and practical aspects of daily life and how reasonable and prudent people act”)(quoting, Stokes, 362 Md. at 415 , 765 A.2d at 616 ), a stop can be considered a Terry stop even if the information the police have could more than satisfy the standard of reas

2003What is clear, however, is that although it is “a less demanding standard than probable cause,” Id. (quoting Illinois v. Wardlow, 528 U.S. 119, 123 , 120 S.Ct. 673, 675-76 , 145 L.Ed.2d 570, 576 (2000)); see also David S., 367 Md. at 532 , 789 A.2d at 612 (reasonable suspicion is “a common sense, nontechnical conception that considers factual and practical aspects of daily life and how reasonable and prudent people act”)(quoting, Stokes, 362 Md. at 415 , 765 A.2d at 616 ), a stop can be considered a Terry stop even if the information the police have could more than satisfy the standard of reas

2013And reasonable suspicion requires “more than a mere hunch but is ‘a less demanding standard than probable cause and requires a showing considerably less than preponderance of the evidence.’ ” Nathan v. State, 370 Md. 648, 663 , 805 A.2d 1086 (2002) (quoting Illinois v. Wardlow, 528 U.S. 119, 123 , 120 S.Ct. 673 , 145 L.Ed.2d 570 (2000)).

2013And reasonable suspicion requires “more than a mere hunch but is ‘a less demanding standard than probable cause and requires a showing considerably less than preponderance of the evidence.’ ” Nathan v. State, 370 Md. 648, 663 , 805 A.2d 1086 (2002) (quoting Illinois v. Wardlow, 528 U.S. 119, 123 , 120 S.Ct. 673 , 145 L.Ed.2d 570 (2000)).

2013We have described the standard as a “common sense, nontechnical conception that considers factual and practical aspects of daily life and how reasonable and prudent people act.” Crosby, 408 Md. at 507 , 970 A.2d 894 (quoting Bost v. State, 406 Md. 341, 356 , 958 A.2d 356 (2008)). ‘While the level of required suspicion is less than that required by the probable cause standard, reasonable suspicion nevertheless embraces something more than an ‘inchoate and unparticularized suspicion or hunch.’ ” Id. (quoting Terry, 392 U.S. at 27 , 88 S.Ct. 1868 ) (internal quotations omitted); see also Alabama

2013We have described the standard as a “common sense, nontechnical conception that considers factual and practical aspects of daily life and how reasonable and prudent people act.” Crosby, 408 Md. at 507 , 970 A.2d 894 (quoting Bost v. State, 406 Md. 341, 356 , 958 A.2d 356 (2008)). ‘While the level of required suspicion is less than that required by the probable cause standard, reasonable suspicion nevertheless embraces something more than an ‘inchoate and unparticularized suspicion or hunch.’ ” Id. (quoting Terry, 392 U.S. at 27 , 88 S.Ct. 1868 ) (internal quotations omitted); see also Alabama

2022We have recognized, in line with United States Supreme Court precedent, that: Reasonable suspicion is a less demanding standard than probable cause not only in the sense that reasonable suspicion can be established with information that is different in quantity or content than that required to establish probable cause, but also in the sense that reasonable suspicion can arise from information that is less reliable than that required to show probable cause[.] Cartnail v. State, 359 Md. 272, 287 , 753 A.2d 519, 527 (2000) (quoting Alabama v. White, 496 U.S. 325, 330 , 110 S. Ct. 2412, 2416 (1990

2022We have recognized, in line with United States Supreme Court precedent, that: Reasonable suspicion is a less demanding standard than probable cause not only in the sense that reasonable suspicion can be established with information that is different in quantity or content than that required to establish probable cause, but also in the sense that reasonable suspicion can arise from information that is less reliable than that required to show probable cause[.] Cartnail v. State, 359 Md. 272, 287 , 753 A.2d 519, 527 (2000) (quoting Alabama v. White, 496 U.S. 325, 330 , 110 S. Ct. 2412, 2416 (1990

2024Reasonable suspicion “is not a demanding standard, but it does require more than an ‘unparticularized suspicion or hunch.’” Holt v. State, 435 Md. 443, 448 (2013) (quoting Terry v. Ohio, 392 U.S. 1 , 30–31 (1968)).

2024Reasonable suspicion “is not a demanding standard, but it does require more than an ‘unparticularized suspicion or hunch.’” Holt v. State, 435 Md. 443, 448 (2013) (quoting Terry v. Ohio, 392 U.S. 1 , 30–31 (1968)).

2008(Internal citations omitted.) The Court further observed in Toyota Motor that “these terms need to be interpreted strictly to create a demanding standard for qualifying as disabled.” Id. at 197 , 122 S.Ct. 681 .

2008(Internal citations omitted.) The Court further observed in Toyota Motor that “these terms need to be interpreted strictly to create a demanding standard for qualifying as disabled.” Id. at 197 , 122 S.Ct. 681 .

2010The Court noted that, since Bell , “a number of courts [ ] have examined institutional policies attempting to prevent detainees from bringing weapons and contraband into the institution,” and many courts “have required that the strip search be based upon reasonable suspicion that the individual was carrying weapons or contraband at the time of arrest.” Id. at 588-89 , 861 A.2d 62 (citations omitted.) It stated: “Reasonable suspicion has been defined as being more than a ‘mere hunch,’ but is ‘a less demanding standard than probable cause and requires a showing considerably less than preponderan

2010The Court noted that, since Bell , “a number of courts [ ] have examined institutional policies attempting to prevent detainees from bringing weapons and contraband into the institution,” and many courts “have required that the strip search be based upon reasonable suspicion that the individual was carrying weapons or contraband at the time of arrest.” Id. at 588-89 , 861 A.2d 62 (citations omitted.) It stated: “Reasonable suspicion has been defined as being more than a ‘mere hunch,’ but is ‘a less demanding standard than probable cause and requires a showing considerably less than preponderan

2007See United States v. Sokolow, 490 U.S. 1, 7 , 109 S.Ct. 1581, 1585 , 104 L.Ed.2d 1, 10 (1989) (explaining that reasonable suspicion is a less demanding standard than probable cause); see also Quince, 319 Md. 430, 433 , 572 A.2d 1086, 1088 (holding that the level of suspicion required for a stop is less demanding than that for probable cause), Watkins v. State, 288 Md. 597, 606 , 420 A.2d 270, 275 (1980) (holding that the reasonable suspicion justifying an investigative stop involves a significantly lower degree of objective evidentiary justification than does a probable cause for arrest).

2007See United States v. Sokolow, 490 U.S. 1, 7 , 109 S.Ct. 1581, 1585 , 104 L.Ed.2d 1, 10 (1989) (explaining that reasonable suspicion is a less demanding standard than probable cause); see also Quince, 319 Md. 430, 433 , 572 A.2d 1086, 1088 (holding that the level of suspicion required for a stop is less demanding than that for probable cause), Watkins v. State, 288 Md. 597, 606 , 420 A.2d 270, 275 (1980) (holding that the reasonable suspicion justifying an investigative stop involves a significantly lower degree of objective evidentiary justification than does a probable cause for arrest).

2025The Werbowsky opinion thoroughly examined the opinions cited by the shareholders (see Werbowsky v. Collomb, 362 Md. at 604, 606-07 ), but ultimately established a more demanding standard for futility.

2025See Danielewicz v. Arnold, 137 Md.

2019See, e.g., id. at 273. “[T]o show constructive knowledge, [an] invitee must demonstrate that [the] defective condition the circuit court’s [grant of summary] judgment because, even with Mrs. Richardson’s having invitee status, appellants failed to make a prima facie showing of negligence.”) 13 Maryland Courts of Appeal have repeatedly cited the Restatement (Second) of Torts with approval in the context of premises liability.

2019See Richardson, 184 Md.