reasonable suspicion standard (Oregon) · Go Syfert
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reasonable suspicion standard in Oregon

53 Oregon opinions name it 2 courts 1978–2026 21 in the last five years

The cases below were cited by Oregon 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 (37)

CaseFollowedCited
State v. Batesgreen
or · 1987 · cited in 3 Oregon opinions naming this issue, 2021–2023
2 sentences

2023See State v. Bates, 304 Or 519, 524 , 747 P2d 991 (1987) (explaining the officer-safety exception to the warrant requirement); see also State v. Watson, 353 Or 768, 773-74 , 305 P3d 94 (2013) (explaining the reasonable suspicion exception).

2023See State v. Bates, 304 Or 519, 524 , 747 P2d 991 (1987) (explaining the officer-safety exception to the warrant requirement); see also State v. Watson, 353 Or 768, 773-74 , 305 P3d 94 (2013) (explaining the reasonable suspicion exception).

33
State v. Watsongreen
or · 2013 · cited in 3 Oregon opinions naming this issue, 2017–2023
2 sentences

2023See State v. Bates, 304 Or 519, 524 , 747 P2d 991 (1987) (explaining the officer-safety exception to the warrant requirement); see also State v. Watson, 353 Or 768, 773-74 , 305 P3d 94 (2013) (explaining the reasonable suspicion exception).

2023See State v. Bates, 304 Or 519, 524 , 747 P2d 991 (1987) (explaining the officer-safety exception to the warrant requirement); see also State v. Watson, 353 Or 768, 773-74 , 305 P3d 94 (2013) (explaining the reasonable suspicion exception).

33
State v. Maciel-Figueroagreen
or · 2017 · cited in 8 Oregon opinions naming this issue, 2019–2025
2 sentences

2025Oregon case law on the reasonable-suspicion standard “has developed over the last half-century based in part on an officer’s statutory authority to conduct a criminal investigative stop and in part on the constitutional limits that Article I, section 9, imposes on that authority.” Maciel-Figueroa, 361 Or at 172 .

2025Oregon case law on the reasonable-suspicion standard “has developed over the last half-century based in part on an officer’s statutory authority to conduct a criminal investigative stop and in part on the constitutional limits that Article I, section 9, imposes on that authority.” Maciel-Figueroa, 361 Or at 172 .

28
State v. Holdorfgreen
or · 2014 · cited in 6 Oregon opinions naming this issue, 2016–2026
2 sentences

2026Certainly, the reasonable suspicion standard includes “a proper regard for the experience that police officers bring with them when Nonprecedential Memo Op: 347 Or App 831 (2026) 835 they encounter criminal suspects.” State v. Holdorf, 355 Or 812, 827-28 , 333 P3d 982 (2014).

2026Certainly, the reasonable suspicion standard includes “a proper regard for the experience that police officers bring with them when Nonprecedential Memo Op: 347 Or App 831 (2026) 835 they encounter criminal suspects.” State v. Holdorf, 355 Or 812, 827-28 , 333 P3d 982 (2014).

26
State v. Reichgreen
orctapp · 2017 · cited in 3 Oregon opinions naming this issue, 2018–2022
2 sentences

2022See, e.g., State v. Messer, 71 Or App 506, 509 , 692 P2d 713 (1984) (explaining that not all “persons who sit in vehicles in parking lots at odd hours of the night or morning * * * render themselves suspect and subject to 46 State v. Miller being stopped by a passing police officer” (footnote omitted)); State v. Morfin-Estrada, 251 Or App 158, 168-69 , 283 P3d 378 , rev den, 352 Or 565 (2012) (collecting cases that recog- nize reasonable suspicion cannot be based entirely on a per- son’s appearance); State v. Reich, 287 Or App 292, 299 , 403 P3d 448 (2017) (observing that “nervous behavior add

2022See, e.g., State v. Messer, 71 Or App 506, 509 , 692 P2d 713 (1984) (explaining that not all “persons who sit in vehicles in parking lots at odd hours of the night or morning * * * render themselves suspect and subject to 46 State v. Miller being stopped by a passing police officer” (footnote omitted)); State v. Morfin-Estrada, 251 Or App 158, 168-69 , 283 P3d 378 , rev den, 352 Or 565 (2012) (collecting cases that recog- nize reasonable suspicion cannot be based entirely on a per- son’s appearance); State v. Reich, 287 Or App 292, 299 , 403 P3d 448 (2017) (observing that “nervous behavior add

23
State v. Westcottgreen
orctapp · 2016 · cited in 2 Oregon opinions naming this issue, 2021–2021
2 sentences

2021See, e.g., State v. Westcott, 282 Or App 614, 619 , 385 P3d 1268 (2016), rev den, 361 Or 486 (2017) (“Nor is it particularly significant in the abstract that defendant had recently left a location known for drug sales.”); State v. Barber, 279 Or App 84, 95 , 379 P3d 651 (2016) (“The fact that defendant and his companion were staying at the motel, which Morrison knew to be a frequent site of drug activity, contributes only minimally to our analysis.”); State v. Wiggins, 262 Or App 351, 361 , 324 P3d 626 (2014) (“As an initial matter, two of those circumstances—viz., defendant’s presence in a ‘h

2021See, e.g., State v. Westcott, 282 Or App 614, 619 , 385 P3d 1268 (2016), rev den, 361 Or 486 (2017) (“Nor is it particularly significant in the abstract that defendant had recently left a location known for drug sales.”); State v. Barber, 279 Or App 84, 95 , 379 P3d 651 (2016) (“The fact that defendant and his companion were staying at the motel, which Morrison knew to be a frequent site of drug activity, contributes only minimally to our analysis.”); State v. Wiggins, 262 Or App 351, 361 , 324 P3d 626 (2014) (“As an initial matter, two of those circumstances—viz., defendant’s presence in a ‘h

22
State v. Kennedygreen
or · 1981 · cited in 2 Oregon opinions naming this issue, 2017–2020
2 sentences

2020See State v. Kennedy, 45 Or App 911, 918 , 609 P2d 438 (1980), rev’d on other grounds, 290 Or 493 , 624 P2d 99 (1981) (concluding facts that the defendant paid for his airline ticket with cash and had a “large amount” of cash on him did not support reasonable suspicion that he was a drug smuggler because 68 State v. Taylor “[i]t is still legal to pay with cash rather than by credit card, and we have no idea how much money a ‘large amount’ is”).3 While we do not rule out the possibility that possessing a large quantity of cash could lead to reasonable suspicion of criminal activity on some othe

2020See State v. Kennedy, 45 Or App 911, 918 , 609 P2d 438 (1980), rev’d on other grounds, 290 Or 493 , 624 P2d 99 (1981) (concluding facts that the defendant paid for his airline ticket with cash and had a “large amount” of cash on him did not support reasonable suspicion that he was a drug smuggler because 68 State v. Taylor “[i]t is still legal to pay with cash rather than by credit card, and we have no idea how much money a ‘large amount’ is”).3 While we do not rule out the possibility that possessing a large quantity of cash could lead to reasonable suspicion of criminal activity on some othe

22
State v. Espinoza-Barragangreen
orctapp · 2012 · cited in 2 Oregon opinions naming this issue, 2013–2020
2 sentences

2020See, e.g., State v. Reich, 287 Or App 292, 299 , 403 P3d 448 (2017) (“We have repeatedly stated that nervous behavior adds little to the reasonable suspicion inquiry.”); State v. Espinoza-Barragan, 253 Or App 743, 750 , 293 P3d 1072 (2012) (“[N]ervousness during a traffic stop contributes little, if any, weight toward reasonable suspicion that the driver is engaged in criminal activity.”); State v. Kentopp, 251 Or App 527, 532 , 284 P3d 564 (2012) (the fact that the defendant’s nervous demeanor was not tied to anything in particular, and could be ascribed 72 State v. Taylor to “any number of t

2020See, e.g., State v. Reich, 287 Or App 292, 299 , 403 P3d 448 (2017) (“We have repeatedly stated that nervous behavior adds little to the reasonable suspicion inquiry.”); State v. Espinoza-Barragan, 253 Or App 743, 750 , 293 P3d 1072 (2012) (“[N]ervousness during a traffic stop contributes little, if any, weight toward reasonable suspicion that the driver is engaged in criminal activity.”); State v. Kentopp, 251 Or App 527, 532 , 284 P3d 564 (2012) (the fact that the defendant’s nervous demeanor was not tied to anything in particular, and could be ascribed 72 State v. Taylor to “any number of t

22
State v. Villegas-Varelagreen
orctapp · 1994 · cited in 2 Oregon opinions naming this issue, 1997–2015
2 sentences

2015See State v. Villegas-Varela, 132 Or App 112, 115 , 887 P2d 809 (1994) (describing three-factor test for determining whether an informant’s report contains sufficient indicia of reliability to create reasonable suspicion); cf. State v. Guggenmos, 350 Or 243, 256 , 253 P3d 1042 (2011) (observing that the reasonable suspicion standard “permits an invasion of privacy * * * on the basis of an informant’s report that is different in quantity or content than probable cause might require”).

2015See State v. Villegas-Varela, 132 Or App 112, 115 , 887 P2d 809 (1994) (describing three-factor test for determining whether an informant’s report contains sufficient indicia of reliability to create reasonable suspicion); cf. State v. Guggenmos, 350 Or 243, 256 , 253 P3d 1042 (2011) (observing that the reasonable suspicion standard “permits an invasion of privacy * * * on the basis of an informant’s report that is different in quantity or content than probable cause might require”).

22
State v. Valdezgreen
or · 1977 · cited in 7 Oregon opinions naming this issue, 1978–2026
2 sentences

2017In Lichty , the court expressly stated the reasonable-suspicion standard, which it described as an “‘objective test of observable facts,”’ 313 Or at 584 (quoting Valdez, 277 Or at 628), in terms of facts giving rise to an inference that criminal activity was afoot, leaving the defendant’s involvement implied: “If a police officer ‘is able to point to specific and articulable facts which give rise to the inference that criminal activity is afoot, the officer has ‘reasonable suspicion’ and hence can stop the individual for investigation.’ State v. Valdez, ⅝⅝⅜ 277 Or at 626 (quoting the Commentar

2017In Lichty , the court expressly stated the reasonable-suspicion standard, which it described as an “‘objective test of observable facts,”’ 313 Or at 584 (quoting Valdez, 277 Or at 628), in terms of facts giving rise to an inference that criminal activity was afoot, leaving the defendant’s involvement implied: “If a police officer ‘is able to point to specific and articulable facts which give rise to the inference that criminal activity is afoot, the officer has ‘reasonable suspicion’ and hence can stop the individual for investigation.’ State v. Valdez, ⅝⅝⅜ 277 Or at 626 (quoting the Commentar

17
State v. Clomangreen
or · 1969 · cited in 4 Oregon opinions naming this issue, 2011–2025
2 sentences

2025The statutes governing investigatory stops were a legislative effort to codify the constitutional limitations that the United States Supreme Court had adopted under the Fourth Amendment in Terry v. Ohio, 392 US 1 , 88 S Ct 1868 , 20 L Ed 2d 889 (1968), and that this court had adopted under Article I, section 9, in State v. Cloman, 254 Or 1, 6 , 456 P2d 67 (1969).

2017The reasonable-suspicion standard balances “the practical necessities of effective law enforcement,” Cloman, 254 Or at 8 (internal quotation marks and citation omitted), with the need “to prevent arbitrary and oppressive interference by [law] enforcement officials with the privacy and personal security of individuals,” Fair, 353 Or at 602 (internal quotation marks and citation omitted).

14
State v. Beltgreen
or · 1997 · cited in 3 Oregon opinions naming this issue, 2010–2017
2 sentences

2017In applying those principles concerning the reasonable-suspicion standard, the court further explained *178 that the objective review of the basis for a stop “looks to the totality of the circumstances confronting a police officer and not just those circumstances that directly relate to a suspect or are personally observed by the police officer stopping a suspect.” Id. at 824 ; accord Belt, 325 Or at 13 (in determining whether an officer had “reasonable suspicion,” a court must first look to the officer’s actual belief, and then evaluate whether that belief was objectively reasonable under the

2012State v. Belt, 325 Or 6, 11 , 932 P2d 1177 (1997).” State v. Levias, 239 Or App 116, 121-22 , 243 P3d 880 (2010), adh’d to as modified on recons, 242 Or App 264 , 255 P3d 611 (2011).

13
State v. Messergreen
orctapp · 1984 · cited in 2 Oregon opinions naming this issue, 2005–2022
2 sentences

2022See, e.g., State v. Messer, 71 Or App 506, 509 , 692 P2d 713 (1984) (explaining that not all “persons who sit in vehicles in parking lots at odd hours of the night or morning * * * render themselves suspect and subject to 46 State v. Miller being stopped by a passing police officer” (footnote omitted)); State v. Morfin-Estrada, 251 Or App 158, 168-69 , 283 P3d 378 , rev den, 352 Or 565 (2012) (collecting cases that recog- nize reasonable suspicion cannot be based entirely on a per- son’s appearance); State v. Reich, 287 Or App 292, 299 , 403 P3d 448 (2017) (observing that “nervous behavior add

2022See, e.g., State v. Messer, 71 Or App 506, 509 , 692 P2d 713 (1984) (explaining that not all “persons who sit in vehicles in parking lots at odd hours of the night or morning * * * render themselves suspect and subject to 46 State v. Miller being stopped by a passing police officer” (footnote omitted)); State v. Morfin-Estrada, 251 Or App 158, 168-69 , 283 P3d 378 , rev den, 352 Or 565 (2012) (collecting cases that recog- nize reasonable suspicion cannot be based entirely on a per- son’s appearance); State v. Reich, 287 Or App 292, 299 , 403 P3d 448 (2017) (observing that “nervous behavior add

12
State v. Taylorgreen
orctapp · 2020 · cited in 2 Oregon opinions naming this issue, 2021–2021
2 sentences

2021See, e.g., State v. Taylor, 308 Or App 61, 71 , 479 P3d 620 (2020) (“Without a link between defendant’s nervousness and any fact supporting objectively reasonable suspicion of drug possession, nervousness, even extreme nervousness, is relatively meaningless to our reasonable suspicion analysis.”).

2021See, e.g., State v. Taylor, 308 Or App 61, 71 , 479 P3d 620 (2020) (“Without a link between defendant’s nervousness and any fact supporting objectively reasonable suspicion of drug possession, nervousness, even extreme nervousness, is relatively meaningless to our reasonable suspicion analysis.”).

12
State v. T. T.green
orctapp · 2021 · cited in 2 Oregon opinions naming this issue, 2021–2021
2 sentences

2021T., 308 Or App 408 , 436 n 4, 479 P3d 598 (2021) (“Analogously, we have repeatedly held that observations of a suspect going to, or coming from, a known drug house, or their presence in a high crime area bear minimal weight in a reasonable suspicion analysis.”).

2021T., 308 Or App 408 , 436 n 4, 479 P3d 598 (2021) (“Analogously, we have repeatedly held that observations of a suspect going to, or coming from, a known drug house, or their presence in a high crime area bear minimal weight in a reasonable suspicion analysis.”).

12
State v. Kreisgreen
or · 2019 · cited in 2 Oregon opinions naming this issue, 2021–2021
2 sentences

2021“The officer must have a subjective belief that the person stopped has committed, or is about to commit, a crime, and that belief must be objec- tively reasonable under the totality of the circumstances.” State v. Kreis, 365 Or 659, 665 , 451 P3d 954 (2019).

2021“The officer must have a subjective belief that the person stopped has committed, or is about to commit, a crime, and that belief must be objec- tively reasonable under the totality of the circumstances.” State v. Kreis, 365 Or 659, 665 , 451 P3d 954 (2019).

12
State v. Worthingtongreen
orctapp · 2014 · cited in 2 Oregon opinions naming this issue, 2018–2019
2 sentences

2019Defendant also contends that Waterbury's suspicion was not objectively reasonable because "defendant's demeanor was at odds with the behavior expected of a suspect who just committed a crime": He "did not run away or attempt to evade Waterbury." Although we agree that a defendant's "suspicious behavior * * * [is an] appropriate factor[ ] to consider along with other evidence" in evaluating whether an officer's suspicion is objectively reasonable, State v. Worthington , 265 Or.

2018See State v. Worthington , 265 Or.App. 368 , 371, 335 P.3d 348 (2014), rev. den. , 356 Or. 837 , 346 P.3d 496 , rev. den. , 357 Or. 300 , 353 P.3d 595 (2015) ("Only those facts available before the stop are considered to evaluate whether the officer's suspicion was reasonable.").

12
State v. Huffmangreen
orctapp · 2015 · cited in 2 Oregon opinions naming this issue, 2017–2018
2 sentences

2018That is, although there is nothing inherently suspicious about a person being nervous when pulled over, this defendant's "distracting conduct in leaving the car provided [the officer] with an indication of why he might be nervous-that he was trying to hide something." Id. at 314 , 360 P.3d 707 .

2018That is, although there is nothing inherently suspicious about a person being nervous when pulled over, this defendant's "distracting conduct in leaving the car provided [the officer] with an indication of why he might be nervous-that he was trying to hide something." Id. at 314 , 360 P.3d 707 .

12
State v. Lichtygreen
or · 1992 · cited in 2 Oregon opinions naming this issue, 2016–2017
2 sentences

2017In Lichty , the court expressly stated the reasonable-suspicion standard, which it described as an “‘objective test of observable facts,”’ 313 Or at 584 (quoting Valdez, 277 Or at 628), in terms of facts giving rise to an inference that criminal activity was afoot, leaving the defendant’s involvement implied: “If a police officer ‘is able to point to specific and articulable facts which give rise to the inference that criminal activity is afoot, the officer has ‘reasonable suspicion’ and hence can stop the individual for investigation.’ State v. Valdez, ⅝⅝⅜ 277 Or at 626 (quoting the Commentar

2017In State v. Jacobus, 318 Or 234, 239-41 , 864 P2d 861 (1993), the court reiterated that facts and reasonable inferences are required, and then it returned to Lichty to finish its formulation of the reasonable-suspicion standard: Reasonable suspicion exists if “the facts known at the time of the stop, combined with the inferences that the police officer reasonably drew from those facts, were sufficient to give rise to ‘reasonable suspicion’ by the officer that ‘criminal activity was afoot.’” Id. at 239 (quoting Lichty, 313 Or at 584 (emphasis added)).

12
State v. Alvaradogreen
orctapp · 2013 · cited in 2 Oregon opinions naming this issue, 2016–2017
2 sentences

2017State v. Dawson, 282 Or App 335, 342 , 386 P3d 165 (2016); see, e.g., State v. Bray, 281 Or App 435, 447 , 380 P3d 1245 (2016) (explaining that “‘nervousness alone is entitled to little weight when evaluating reasonable suspicion’”) (quoting State v. Huffman, 274 Or App 308, 314 , 360 P3d 707 (2015), rev den, 358 Or 550 (2016)); State v. Alvarado, 257 Or App 612, 629 , 307 P3d 540 (2013) (concluding that “defendant’s anxious behaviors contribute very little to our reasonable suspicion calculus”).

2017State v. Dawson, 282 Or App 335, 342 , 386 P3d 165 (2016); see, e.g., State v. Bray, 281 Or App 435, 447 , 380 P3d 1245 (2016) (explaining that “‘nervousness alone is entitled to little weight when evaluating reasonable suspicion’”) (quoting State v. Huffman, 274 Or App 308, 314 , 360 P3d 707 (2015), rev den, 358 Or 550 (2016)); State v. Alvarado, 257 Or App 612, 629 , 307 P3d 540 (2013) (concluding that “defendant’s anxious behaviors contribute very little to our reasonable suspicion calculus”).

12
State v. Wamplergreen
orctapp · 2023 · cited in 1 Oregon opinions naming this issue, 2025–2025
2 sentences

2025That inference must be objectively reasonable in light of the totality of cir- cumstances known to the officer.” State v. Wicks, 332 Or App 67 , 69-70, 549 P3d 49 (2024) (internal quotation marks and citation omitted); see also State v. Wampler, 325 Or App 722, 727 , 530 P3d 133 , rev den, 371 Or 477 (2023) (“[R]easonable suspicion is a relatively low barrier, and the reasonable suspicion standard includes a proper regard for the experience that police officers bring Nonprecedential Memo Op: 338 Or App 491 (2025) 493 with them when they encounter criminal suspects.” (Internal quotation marks o

2025That inference must be objectively reasonable in light of the totality of cir- cumstances known to the officer.” State v. Wicks, 332 Or App 67 , 69-70, 549 P3d 49 (2024) (internal quotation marks and citation omitted); see also State v. Wampler, 325 Or App 722, 727 , 530 P3d 133 , rev den, 371 Or 477 (2023) (“[R]easonable suspicion is a relatively low barrier, and the reasonable suspicion standard includes a proper regard for the experience that police officers bring Nonprecedential Memo Op: 338 Or App 491 (2025) 493 with them when they encounter criminal suspects.” (Internal quotation marks o

11
State v. Shermangreen
orctapp · 2015 · cited in 1 Oregon opinions naming this issue, 2022–2022
11
State v. Jimenezgreen
or · 2015 · cited in 1 Oregon opinions naming this issue, 2022–2022
11
State v. Barbergreen
orccmarion · 2016 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
State v. Arivettgreen
orctapp · 2021 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
United States of America,plaintiff-Appellee v. Armando Lopez-Sotogreen
ca9 · 2000 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
State v. Wigginsgreen
orctapp · 2014 · cited in 1 Oregon opinions naming this issue, 2021–2021
11
State v. Kennedygreen
orctapp · 1980 · cited in 1 Oregon opinions naming this issue, 2020–2020
11
State v. Fairgreen
or · 2013 · cited in 1 Oregon opinions naming this issue, 2017–2017
11
State v. Braygreen
orctapp · 2016 · cited in 1 Oregon opinions naming this issue, 2017–2017
11
State v. Taylorgreen
or · 2010 · cited in 1 Oregon opinions naming this issue, 2016–2016
11
State v. Meza-Garciagreen
orctapp · 2013 · cited in 1 Oregon opinions naming this issue, 2016–2016
11
State v. Juarez-Godinezgreen
or · 1997 · cited in 1 Oregon opinions naming this issue, 2013–2013
11
State v. Ashbaughgreen
or · 2010 · cited in 1 Oregon opinions naming this issue, 2011–2011
11
State v. Hallgreen
or · 2005 · cited in 1 Oregon opinions naming this issue, 2011–2011
11
State v. Gamboagreen
or · 2006 · cited in 1 Oregon opinions naming this issue, 2008–2008
11
Cibula v. Driver & Motor Vehicle Services Branchgreen
orctapp · 2005 · cited in 1 Oregon opinions naming this issue, 2008–2008
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (36)

CaseCitedYears
Terry v. Ohio green
scotus · 1968
2 sentences

2025The statutes governing investigatory stops were a legislative effort to codify the constitutional limitations that the United States Supreme Court had adopted under the Fourth Amendment in Terry v. Ohio, 392 US 1 , 88 S Ct 1868 , 20 L Ed 2d 889 (1968), and that this court had adopted under Article I, section 9, in State v. Cloman, 254 Or 1, 6 , 456 P2d 67 (1969).

2025The statutes governing investigatory stops were a legislative effort to codify the constitutional limitations that the United States Supreme Court had adopted under the Fourth Amendment in Terry v. Ohio, 392 US 1 , 88 S Ct 1868 , 20 L Ed 2d 889 (1968), and that this court had adopted under Article I, section 9, in State v. Cloman, 254 Or 1, 6 , 456 P2d 67 (1969).

32017–2025
State v. Ehly green
or · 1993
2 sentences

2001In State v. Ehly, 317 Or 66, 80 , 854 P2d 421 (1993), the court summarized the reasonable suspicion inquiry under ORS 131.615: “The statutory standard for the stopping and questioning of a person concerning his or her possible criminal activity was intended to be less than the standard for probable cause to arrest.

2001In State v. Ehly, 317 Or 66, 80 , 854 P2d 421 (1993), the court summarized the reasonable suspicion inquiry under ORS 131.615: “The statutory standard for the stopping and questioning of a person concerning his or her possible criminal activity was intended to be less than the standard for probable cause to arrest.

31997–2016
State v. Moore green
orctapp · 2021
2 sentences

2026The officer must have a “sub- jective belief that the person stopped has committed, or is about to commit, a crime, and that belief must be objectively reasonable under the totality of the circumstances.” Moore, 311 Or App at 18 .

2026The officer must have a “sub- jective belief that the person stopped has committed, or is about to commit, a crime, and that belief must be objectively reasonable under the totality of the circumstances.” Moore, 311 Or App at 18 .

22026–2026
State v. Duffee green
orctapp · 2024
2 sentences

2024However, based on 2 Article I, section 9, provides, as relevant: “No law shall violate the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable search, or seizure[.]” Cite as 336 Or App 763 (2024) 767 the lack of documentation, the suspicious trip permit, the passenger in the truck bed leaving the scene, and impor- tantly, defendant’s claim to own the vehicle, the officer rea- sonably inferred that defendant was in possession of a stolen vehicle.

2024However, based on 2 Article I, section 9, provides, as relevant: “No law shall violate the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable search, or seizure[.]” Cite as 336 Or App 763 (2024) 767 the lack of documentation, the suspicious trip permit, the passenger in the truck bed leaving the scene, and impor- tantly, defendant’s claim to own the vehicle, the officer rea- sonably inferred that defendant was in possession of a stolen vehicle.

22024–2024
State v. Keck neutral
orctapp · 2023
2 sentences

2023The parties’ dispute centers on whether officer- safety concerns or reasonable suspicion permitted McBride’s actions—asking about weapons, ordering defendant out of Cite as 328 Or App 296 (2023) 303 the truck, handcuffing and patting him down—which led to the discovery of the revolver that prompted defendant’s arrest and conviction.

2023The parties’ dispute centers on whether officer- safety concerns or reasonable suspicion permitted McBride’s actions—asking about weapons, ordering defendant out of Cite as 328 Or App 296 (2023) 303 the truck, handcuffing and patting him down—which led to the discovery of the revolver that prompted defendant’s arrest and conviction.

22023–2023
State v. Kentopp green
orctapp · 2012
2 sentences

2020See, e.g., State v. Reich, 287 Or App 292, 299 , 403 P3d 448 (2017) (“We have repeatedly stated that nervous behavior adds little to the reasonable suspicion inquiry.”); State v. Espinoza-Barragan, 253 Or App 743, 750 , 293 P3d 1072 (2012) (“[N]ervousness during a traffic stop contributes little, if any, weight toward reasonable suspicion that the driver is engaged in criminal activity.”); State v. Kentopp, 251 Or App 527, 532 , 284 P3d 564 (2012) (the fact that the defendant’s nervous demeanor was not tied to anything in particular, and could be ascribed 72 State v. Taylor to “any number of t

2020See, e.g., State v. Reich, 287 Or App 292, 299 , 403 P3d 448 (2017) (“We have repeatedly stated that nervous behavior adds little to the reasonable suspicion inquiry.”); State v. Espinoza-Barragan, 253 Or App 743, 750 , 293 P3d 1072 (2012) (“[N]ervousness during a traffic stop contributes little, if any, weight toward reasonable suspicion that the driver is engaged in criminal activity.”); State v. Kentopp, 251 Or App 527, 532 , 284 P3d 564 (2012) (the fact that the defendant’s nervous demeanor was not tied to anything in particular, and could be ascribed 72 State v. Taylor to “any number of t

22015–2020
State v. Mitchele green
orctapp · 2010
2 sentences

2016In at least some circumstances, the answer is “yes.” For example, in State v. Mitchele, 240 Or App 86, 88 , 251 P3d 760 (2010), a named informant reported that a person, whom the informant described, was “possibly casing, walking up and down [the] street, [and] looking at homes.” (Brackets in original.) Police officers stopped the defendant based largely on that report and eventually discovered that he possessed methamphetamine; he was convicted of that crime following the denial of his motion to suppress.

2016In at least some circumstances, the answer is “yes.” For example, in State v. Mitchele, 240 Or App 86, 88 , 251 P3d 760 (2010), a named informant reported that a person, whom the informant described, was “possibly casing, walking up and down [the] street, [and] looking at homes.” (Brackets in original.) Police officers stopped the defendant based largely on that report and eventually discovered that he possessed methamphetamine; he was convicted of that crime following the denial of his motion to suppress.

22012–2016
AFSCME Local 2623 v. Department of Corrections green
or · 1992
2 sentences

2011The court held in AFSCME Local 2623 v. Dept. of Corrections, 315 Or 74 , 843 P2d 409 (1992), that a reasonable suspicion standard contained within an administrative search policy for prison employees, as set forth in department administrative rules, did not violate the employees’ rights under Article I, section 9.

2011The court held in AFSCME Local 2623 v. Dept. of Corrections, 315 Or 74 , 843 P2d 409 (1992), that a reasonable suspicion standard contained within an administrative search policy for prison employees, as set forth in department administrative rules, did not violate the employees’ rights under Article I, section 9.

22011–2011
State v. Bagnall neutral
orctapp · 2026
1 sentence

2026Certainly, the reasonable suspicion standard includes “a proper regard for the experience that police officers bring with them when Nonprecedential Memo Op: 347 Or App 831 (2026) 835 they encounter criminal suspects.” State v. Holdorf, 355 Or 812, 827-28 , 333 P3d 982 (2014).

12026–2026
State v. Savannah neutral
orctapp · 2025
12025–2025
State v. Roberts neutral
orctapp · 2020
12023–2023
State v. Morfin-Estrada green
orctapp · 2012
12022–2022
State v. Oller green
orctapp · 2016
12022–2022
State v. Sexton neutral
orccwashington · 2016
12021–2021
State v. Bowen green
orctapp · 2021
12021–2021
State v. Hammonds green
orctapp · 1998
12021–2021
State v. Maciel green
orctapp · 2013
12021–2021
State v. Martin green
orctapp · 2014
12021–2021
State v. Davis green
orctapp · 2017
12021–2021
State v. Gulley green
or · 1996
12021–2021
State v. Richards green
orctapp · 1982
12019–2019
State v. Jacobus green
or · 1993
12017–2017
State v. Dawson green
orctapp · 2016
12017–2017
State v. Ruiz green
orctapp · 2004
12017–2017
State v. Berry green
orctapp · 2009
12016–2016
State v. Bybee green
orctapp · 1994
12016–2016
State v. Guggenmos green
or · 2011
12015–2015
State v. Butkovich green
orctapp · 1987
12014–2014
State v. Turner green
orctapp · 2008
12014–2014
State v. Juarez-Godinez green
orctapp · 1995
12013–2013
State v. Levias green
orctapp · 2010
12012–2012
State v. Levias green
orctapp · 2011
12012–2012
State v. Ashbaugh green
orctapp · 2008
12011–2011
State v. Amaya green
orctapp · 2001
12001–2001
State v. Shumway green
orctapp · 1993
11997–1997
State v. Black green
orctapp · 1986
11997–1997

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 475.894 (15) OR § Or. Rev. Stat. § 131.605 (13) OR § Or. Rev. Stat. § 131.615 (12) OR § Or. Rev. Stat. § 166.270 (7) OR § Or. Rev. Stat. § 164.245 (4) OR § Or. Rev. Stat. § 166.240 (4) OR § Or. Rev. Stat. § 810.410 (4) OR § Or. Rev. Stat. § 135.335 (3) OR § Or. Rev. Stat. § 164.135 (3) OR § Or. Rev. Stat. § 419A.200 (3) OR § Or. Rev. Stat. § 475.884 (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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