United States v. Sokolow

The court of appeals had ruled that Sokolow was seized by the authorities when they stopped him from hailing a cab outside the Honolulu airport, so the Supreme Court examined whether or not a reasonable suspicion existed that he was engaging in a criminal activity at that time. The Court had already ruled, in case of Terry v. Ohio, that police officers could briefly detain a person given a reasonable suspicion that the person was engaged or preparing to engage in a criminal activity. Furthermore, in Illinois v. Gates (1983), the Court had defined probable cause as: "a fair probability that contraband or evidence of crime will be found" if a search is conducted. While admitting that definitions of reasonable suspicion were highly subjective, the Court believed that the two-pronged evaluation of evidence used by the court of appeals to be even less useful. Writing for the majority, Justice Rehnquist stated that while reasonable suspicion must consist of something more than an "inchoate and unparticularized suspicion," it need not adhere to as strict a scrutiny as the probable cause required to obtain a warrant. In the Court's opinion, the Fourth Amendment required only that authorities show "some minimal level of objective justification" for making a stop, and that this minimal level of justification existed in Sokolow's case. As such, the decision of the court of appeals was reversed and the evidence obtained against Sokolow deemed admissible in court.