On April 20, 2026, the United States Supreme Court issued its decision in District of Columbia v. R.W., No. 25-248, reversing the D.C. Court of Appeals and holding that a Metropolitan Police officer had reasonable suspicion under the Fourth Amendment to stop a juvenile identified as R.W. The 7-2 per curiam opinion reinforces a principle that affects every police stop in America: courts evaluating the lawfulness of a stop must consider the totality of the circumstances, and they cannot selectively exclude individual facts from the analysis.
If you have ever been stopped by police and wondered whether the officer had the legal right to do so (or if you are facing criminal charges where the prosecution’s evidence came from a stop you believe was unlawful) this case is worth understanding. Here is what it means in plain English, and what it means specifically for people stopped in Texas.
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The Background: What Happened in This Case
In February 2023, a D.C. Metropolitan Police officer responded to a radio dispatch about a suspicious vehicle at a specific address in the early morning hours. When the officer arrived at approximately 2:00 a.m., he saw two people immediately flee from the back of the vehicle. As he approached in his patrol car, the driver (R.W.) began backing the car out of its parking space with the rear driver’s side door still open. The officer ordered R.W. to put his hands up, drew his service weapon, and detained him. Evidence found after the stop led to charges of unauthorized use of a motor vehicle, felony receipt of stolen property, unlawful entry of a motor vehicle, and operating without a permit.
R.W. moved to suppress the evidence, arguing the stop was unlawful. The trial court denied the motion, finding that four factors combined to create reasonable suspicion: the radio dispatch, two companions fleeing unprovoked, the late hour, and the car beginning to move while a door was still open. The D.C. Court of Appeals reversed, but it got there through an approach the Supreme Court found fundamentally flawed: it excluded two of the four factors from the analysis before weighing the rest.
What the Supreme Court Actually Decided
The D.C. Court of Appeals had decided to “excise” the radio dispatch call and the flight of R.W.’s companions from its analysis before weighing whether reasonable suspicion existed. Its reasoning: the dispatch call didn’t come with enough information about its source and reliability to deserve full weight, and the companions’ flight shouldn’t count against R.W. because there was no evidence he was acting in concert with them.
The Supreme Court held that this approach was wrong. Under the Fourth Amendment’s Terry v. Ohio framework, courts must assess all the facts known to the officer at the time of the stop and not a curated subset. A court evaluating reasonable suspicion cannot remove individual facts from the scale before weighing the total. Every known fact goes into the analysis. The weight assigned to each fact may vary, but no fact can simply be excluded.
Applying the totality of all four factors, the Court held that Officer Vanterpool clearly had reasonable suspicion. The case was reversed and remanded.
Justice Jackson dissented, arguing that the case was a routine fact-bound determination that didn’t warrant summary reversal by the Supreme Court. Justice Sotomayor did not join the dissent but also opposed the ruling.
The Legal Framework: Terry Stops, Reasonable Suspicion, and Probable Cause
If you are not a lawyer, the vocabulary of Fourth Amendment law can be confusing. These are the key terms:
Terry Stop (Investigative Detention)
Named for Terry v. Ohio, 392 U.S. 1 (1968), a Terry stop is a brief investigative detention by a law enforcement officer. This is the kind of encounter where an officer pulls someone over, orders them to stop walking, or commands them to put their hands up. A Terry stop is not an arrest. The officer does not need to read you Miranda rights, and they do not need to let you go immediately. But they do need legal justification to initiate the stop at all.
Reasonable Suspicion
Reasonable suspicion is the legal standard that justifies a Terry stop. It is less than probable cause and far less than the beyond-a-reasonable-doubt standard required for a conviction. Reasonable suspicion exists when an officer can point to specific, articulable facts that, considered together with reasonable inferences, create an objective basis for suspecting criminal activity may be afoot. A hunch is not enough. A generalized suspicion based on neighborhood or appearance is not enough. There must be something concrete (specific observable facts) that the officer can articulate.
Probable Cause
Probable cause is the higher standard required to make an arrest or to obtain a search warrant. It requires facts and circumstances that would cause a reasonable person to believe that a crime has been committed and that the suspect committed it. Probable cause is more than reasonable suspicion but still less than certainty.
The Totality of the Circumstances Test
Under the totality of the circumstances test, no single factor is determinative. Courts look at the entire picture (every fact the officer knew at the moment of the stop) and ask whether that combined picture objectively justified the stop. Individual facts that might be innocent in isolation can, in combination, amount to reasonable suspicion. As the Court noted in D.C. v. R.W., reasonable suspicion “need not rule out the possibility of innocent conduct.”
What This Ruling Means for Criminal Defense
The D.C. v. R.W. decision cuts in both directions, and it is important to understand both edges.
What It Means Against Defendants
The ruling makes it harder for defense attorneys to get evidence suppressed by arguing that individual factors in a stop were weak or ambiguous. Under the D.C. Court of Appeals’ approach, a defense attorney could argue: “Factor A doesn’t count because the dispatch call lacked corroboration. Factor B doesn’t count because my client’s companions’ behavior shouldn’t be imputed to him. Now look at what’s left.” The Supreme Court has now said that approach is wrong. Everything goes into the balance.
What It Means For Defendants
The same totality rule that prevents courts from excluding prosecution-favorable factors also prevents them from ignoring defense-favorable ones. If the facts the officer “knew” at the time of the stop included circumstances that pointed toward innocence (ex. if there was an obvious innocent explanation for the behavior, if the officer had been given incorrect or unreliable information, if the defendant’s conduct was actually consistent with a lawful activity) those facts also go into the totality analysis.
D.C. v. R.W. reinforces that reasonable suspicion requires specific articulable facts, not a general sense that something looked wrong. The Court did not lower the bar. It clarified that the bar applies to everything the officer actually knew (the full picture, in both directions).
Case Results
How This Applies in Texas: Article 38.23
Texas has its own exclusionary rule (Texas Code of Criminal Procedure Article 38.23) that is in some ways stronger than the federal Fourth Amendment framework. Under Article 38.23, evidence obtained in violation of the Texas or United States Constitutions is inadmissible. Texas has no good faith exception. If the stop was unlawful, the evidence is out.
When a Texas DWI, drug, or criminal defense case begins with a traffic stop or street encounter, the first question the defense asks is: did the officer have lawful justification for the initial stop? The answer to that question determines whether everything that followed (the smell of alcohol, the field sobriety tests, the search of the vehicle, the blood draw) is admissible or suppressible. A successful Article 38.23 suppression motion frequently ends the prosecution entirely.
The holding in D.C. v. R.W. reinforces that the totality-of-the-circumstances analysis in Texas suppression hearings must account for all the facts. That means:
- The defense must develop the full factual record of what the officer knew and didn’t know at the moment of the stop and not just the factors that favor the prosecution.
- Facts suggesting an innocent explanation for the conduct (that the driver was in a well-lit area, that the stop occurred near their home, that the vehicle matched the description of thousands of other vehicles) go into the totality analysis.
- Facts undermining the reliability of the basis for the stop (dispatch calls based on anonymous tips, information from sources with undisclosed credibility) remain part of the analysis and affect the weight assigned to those factors.
- The defense cannot simply pick the weakest factor and argue the rest don’t count. But the prosecution cannot either.
The Bottom Line for Anyone Stopped by Police in Texas
If you have been stopped by law enforcement in Texas (whether in a vehicle, on foot, or on a boat) and charges resulted from that stop, the lawfulness of the initial encounter is one of the first things a defense attorney will examine. A stop that lacked reasonable suspicion, or an arrest that lacked probable cause, may render the evidence obtained from that stop inadmissible under Article 38.23.
That analysis is fact-intensive and must begin early. Evidence of the officer’s actual basis for the stop, their training and experience with the specific factors they observed, what they knew and didn’t know at the moment of contact, and any innocent explanation for the defendant’s conduct. All of it matters.
Deandra Grant Law handles Article 38.23 suppression analysis in every DWI and criminal defense case across North and Central Texas. If you have been charged with an offense that began with a stop you believe was unlawful, call (214) 225-7117 for a free, confidential consultation. Or schedule online at texasdwisite.com.
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