reasonable suspicion standard in South Carolina

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025See White, 496 U.S. at 330 ("Reasonable suspicion, like probable cause, is dependent upon both the content of information possessed by police and its degree of reliability.").

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025Further, this Court has recognized the common usage of the term reasonable, explaining "[t]he objective 'reasonable' test is used in many areas of the law as an appropriate determinant of liability and thus a guide to conduct." Baker, 315 S.C. at 152-53 , 432 S.E.2d at 474 (quoting Eanes, 569 A.2d at 616 ); see e.g., State v. Moore, 415 S.C. 245, 252 , 781 S.E.2d 897, 900 (2016) ("The Fourth Amendment provides in relevant part that '[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated.'" (alterat

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2025As the Indiana Court of Appeals observed "the clear majority trend has recognized that 'unreasonable noise' provisions which are construed only to prohibit unprotected speech are not unconstitutionally vague." Price v. State, 600 N.E.2d 103, 109 (Ind. Ct. App. 1992), aff'd in part, vacated in part, 622 N.E.2d 954 (Ind. 1993); see Cameron v. Johnson, 390 U.S. 611, 616 (1968) (holding the word "unreasonably" was "a widely used and well understood word"); Duhe v. City of Little Rock, 902 F.3d 858, 864 (8th Cir. 2018) (finding the term 'unreasonably' was a "widely understood restriction[]" that re

2020In Illinois v. Wardlow, the United States Supreme Court recognized that "presence in an area of expected criminal activity" and "nervous, evasive behavior" are both relevant—though not dispositive—in a reasonable suspicion analysis. 528 U.S. 119, 124 (2000).

2018See United States v. McCoy , 513 F.3d 405 , 411 (4th Cir. 2008) (stating "the Supreme Court has often counseled lower courts to give 'due weight' to the factual inferences drawn by police officers as they investigate crime, for the reasonable suspicion analysis is by its nature 'officer-centered' " (citations omitted) ).