IL: Mere presence in a high crime area isn’t reasonable suspicion

Mere presence in a high crime area isn’t reasonable suspicion, and defendant was unreasonably seized by police. People v. Williams, 2016 IL App (1st) 132615, 2016 Ill. App. LEXIS 555 (Aug. 19, 2016).

“Reed Dempsey brought a civil rights action under 42 U.S.C. § 1983 against Bucknell University, Bucknell University Public Safety (‘BUPS’) officers, and Bucknell University officials (collectively, the ‘Bucknell Defendants’) claiming violations of his Fourth Amendment right to be free from unlawful search and seizure. Because we agree with the District Court that, even taking into account certain facts recklessly omitted from the affidavit of probable cause, a reasonable jury could not find a lack of probable cause, we will affirm the District Court’s grant of summary judgment in favor of the Bucknell Defendants.” Dempsey v. Bucknell Univ., 2016 U.S. App. LEXIS 15334 (3d Cir. Aug. 22, 2016).

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