Archived SI output (machine-generated)

Officer Vanterpool's stop was an unreasonable seizure without probable cause; D.C. Court of Appeals affirmed, evidence suppressed.

Mode: Scotus Opinion Generated by VFA SI Solutions Drafted: 2026.05.15

Archived SI output (machine-generated) · No editorial review recorded

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Supreme Court opinion

District of Columbia v. R.W.

Per Curiam

Author
Per Curiam
Filed
2026-04-20
Citation
—
→ View original
Archived SI draft (machine-generated)

Officer Vanterpool's stop was an unreasonable seizure without probable cause; D.C. Court of Appeals affirmed, evidence suppressed.

Whether a police officer's brief seizure of a vehicle driver—ordering hands up at gunpoint after a late-night dispatch on a suspicious car, companions fleeing unprovoked, and the driver backing out with door open—violated the Fourth Amendment absent probable cause.

Constitutional concerns with the original

  1. Majority invents 'reasonable suspicion' standard from Terry v. Ohio (1968) and progeny (Arvizu, Sokolow, Wardlow, Wesby), absent from ratification-era text or practice; original Fourth Amendment tolerated no seizures short of probable cause or warrant.
  2. 'Totality of circumstances' and 'commonsense judgments' tests are post-1900 judicial glosses, ignoring textual warrant/probable cause requirement and 1791 understanding that 'seizure' of persons equated to arrests needing oath-based cause.
  3. Dismisses need to 'rule out innocent conduct' via modern balancing, diverging from original bar on presumptive seizures without particularized probable cause.

Solution text

1) The question: Did Officer Vanterpool violate the Fourth Amendment by seizing R.W. without a warrant or probable cause, based on a dispatch, flight by companions, late hour, and backing car with open door? 2) Relevant text: Fourth Amendment: 'The right of the people to be secure in their persons... against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.' Tenth Amendment reserves unenumerated powers like local policing to states/D.C. 3) Ratification-era understanding (1787-1791): 'Seizure' meant control of person/property akin to arrest; required probable cause (reasonable belief of crime) or warrant; barred arbitrary stops by customs officers via writs of assistance; constables acted only on felonies in view, hot pursuit, or breach of peace—no generalized 'suspicion' stops; Framers rejected lesser intrusions to protect liberty. 4) Holding: No probable cause here (no known crime, just odd behavior); ordering hands up while drawing gun was seizure, unreasonable without cause/warrant; suppress evidence, vacate adjudication/probation; Tenth Amendment lets D.C. Council enact rules if text-compliant. 5) Downstream changes: Ends Terry stops nationwide; police limited to consensual talks, probable cause arrests, or warrants; boosts personal security, cuts pretextual policing; invites state experiments (e.g., D.C. probable cause lite via statute, Tenth Amendment).

Operative provisions

remedy
Suppress all evidence from stop; vacate R.W. delinquency finding, probation; remand for release or new proceedings sans fruit.
stare decisis treatment
Overrules Terry v. Ohio (1968) and line (Arvizu, Sokolow, Wardlow, Glover, Wesby) as extra-textual; minimal stare weight given weak originalist basis.
scope of holding
All warrantless investigatory seizures of persons/vehicles require probable cause; consensual encounters ok if truly voluntary.

Bipartisan rationale

Honors Democratic priorities (civil liberties, minority protections from over-policing) and Republican priorities (textual originalism, federalism via Tenth Amendment for states/D.C. to tailor rules); ditches judge-made doctrines both sides critique as unmoored from Constitution.

Constitutional citations

  • → Fourth Amendment
  • → Tenth Amendment

Amendment IV Amendment X

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Generated by VFA SI Solutions · 2026.05.15 06:03 UTC · ← Back to the Republic