Supreme Court of Maryland

Washington v. State

December 19, 2022482 Md. 395

Summary

The court held that the detectives had reasonable articulable suspicion to stop Washington because his repeated, unprovoked, headlong flight, evasive maneuvers, and attempted concealment occurred in a specifically established high-crime area. The court emphasized that unprovoked flight in a high-crime area is not automatically sufficient, but must be evaluated under the totality of the circumstances, including potentially innocent reasons such as fear of police. The court also held that Maryland Declaration of Rights Article 26 provides coextensive protection with the Fourth Amendment in this context.