d have given Officer Smith reasonable suspicion that she was involved in criminal activity. Most notably, she ran from the traffic stop, and she ignored Officer Smith’s commands. In the Wardlow decision, the court held that unprovoked flight, in conjunction with background factors, such as rampant drug trafficking in the neighborhood, can easily lead to reasonable suspicion. Although unprovoked flight does not cause reasonable suspicion on its own, it can go a long way to providing reasonable suspicion. Officer Smith probably drew his reasonable suspicion from the combination of flight from the traffic stop and the disobeying of his commands.Thus, once in the bathroom stall with the client, Officer Smith was free to make his brief investigation. Ms. Jones continued to ignore the officer’s requests, and she would not show the officer her hands. At this point, under Wardlow, the officer was justified in forcing Ms. Jones to show her hands, in order to rule out possession of concealed weapons. Officer Smith was also free to make a protective pat down for weapons. Once the officer subdued Ms. Jones, he placed her under arrest for obstruction of a law enforcement officer. It is as this point that he searched her purse and found the cocaine. If Officer Smith had patted Ms. Jones down, and examined the immediate area around Ms. Jones, he would not have seen anything to raise his level of suspicion to probable cause. The cocaine found on Ms. Jones would not have been uncovered during a pat down, due to its location in her contact case. Thus, Officer Smith actions went further then a standard investigative stop would allow. If the officer had not arrested her, he would have never discovered the cocaine. However, at no point did he have probable cause to make the arrest. Similarly, in the case of Florida v. Royer, 460 U.S. 103 (1983), the Supreme Court held that while investigating a person who is merely suspected of criminal activit...
