High crime area at night, furtive and evasive movements, and nervousness when encountering the officer added up to reasonable suspicion. State v. Barnes, 2016 La. App. LEXIS 1669 (La.App. 1 Cir. Sept. 16, 2016):
When Corporal Pugh exited his unit, the defendant did not stop, apparently feeling that he was not under detention and free to walk away. Corporal Pugh knew the defendant’s companion, Barber, and was aware of Barber’s involvement with narcotics in that particular area. Corporal Pugh yelled at the defendant to come back, effectuating a stop. While Corporal Pugh conceded that he had no tip before the stop, the circumstances known to the officer at the time, including the high-crime characteristics of the area, the defendant and Barber’s nervous and furtive behavior, Barber’s narcotics history in the area, and the defendant’s evasiveness, were sufficient to create an articulable suspicion to stop and detain the defendant. Assuming, arguendo, that the stop was imminent when Corporal Pugh turned his unit around, before exiting his unit, Corporal Pugh had observed both the defendant and Barber repeatedly looking over their shoulders, making surreptitious glances. Corporal Pugh explained that the nervousness by both individuals, coupled with his specific knowledge of robberies, burglaries, drugs and weapon related offenses in the area, led him to turn his vehicle around to approach the individuals. After reviewing the record in this case, we find that Corporal Pugh had reasonable, articulable suspicion of criminal behavior by the defendant to conduct a lawful investigatory stop.