City of St. Paul v. Uber
450 N.W.2d 623, 1990 WL 3409, 1990 Minn. App. LEXIS 93 (1990)
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Rule of Law:
A collection of individually innocent behaviors, such as driving alone late at night in a high-crime area and being from a different town, does not, without more, constitute a reasonable, articulable suspicion of criminal activity sufficient to justify an investigatory vehicle stop under the Fourth Amendment.
Facts:
- At approximately 2:15 a.m., Officer David Mathison first observed Stephen D. Uber driving his pickup truck in the Summit-University area of St. Paul, an area known for prostitution.
- Approximately 30 minutes later, Mathison saw Uber's truck for a second time in the same general area.
- Mathison observed no erratic driving, traffic violations, evasive maneuvers, or any other illegal activity by Uber.
- Uber did not circle any specific block, slow down, stop his vehicle, or attempt to engage in conversation with anyone on the street.
- Mathison radioed in Uber's license plate and learned the vehicle was registered to a person in Moundsview, a suburb about 20 miles away from St. Paul.
- Based on the combination of Uber driving alone, the late hour, his presence in the area twice, and the vehicle's registration to a suburban address, Mathison decided to stop the vehicle on suspicion of activity related to prostitution.
Procedural Posture:
- Stephen D. Uber was arrested and charged with driving after revocation and with an expired license.
- In the trial court, Uber filed a pretrial motion to suppress evidence resulting from the stop, arguing the stop was invalid.
- The trial court denied the motion, finding the stop to be valid.
- After a trial based on stipulated facts, the trial court found Uber guilty of the charges.
- Uber (appellant) appealed his conviction to this court, the intermediate court of appeals.
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Issue:
Does a police officer have a reasonable, articulable suspicion of criminal activity to justify an investigatory stop of a vehicle under the Fourth Amendment when the driver is observed driving lawfully, alone, late at night, in an area known for prostitution, and a license plate check reveals the car is registered to a resident of a different town?
Opinions:
Majority - Randall, J.
No. The stop of the vehicle was not supported by a reasonable, articulable suspicion of criminal activity and therefore violated the Fourth Amendment. The court reasoned that the objective facts articulated by the officer were 'de minimis, and beneath constitutional standards.' Each of the factors cited—driving alone, the late hour, being seen twice in a 30-minute span, and having an out-of-town address—is an innocent activity. Taken together, they do not create a particularized suspicion of wrongdoing. The court distinguished this case from others like United States v. Sokolow, which involved far more suspicious conduct, and State v. Johnson, which involved clear evasive action. The court found that the determinative factor for the officer was the vehicle's suburban registration, which is not a basis for a stop and constitutes an 'invidious form of discrimination.' Simply being a stranger in a high-crime area is insufficient to justify an investigatory stop.
Concurring - Short, J.
No. The judge concurred only with the majority's conclusion that the arresting officer did not have a reasonable suspicion supported by articulable facts that the appellant was engaging in criminal activity.
Analysis:
This decision significantly clarifies the limits of 'profile stops' under the Fourth Amendment. It establishes that a combination of wholly innocent, non-specific behaviors cannot form the basis for reasonable suspicion, even in a high-crime area. The ruling serves as a strong check on police discretion, preventing stops based on the subjective belief that an individual 'does not belong' in a certain neighborhood. By labeling the reliance on an out-of-town address as a form of 'invidious discrimination,' the court signaled that future courts should be highly skeptical of stops based on geographic or demographic assumptions, thereby reinforcing the requirement for particularized, objective evidence of potential wrongdoing.
