DC: Time and proximity to a crime are important in RS, but here it was lacking

Time and proximity are important in the reasonable suspicion calculus. The closer in time with proximity to the scene of a crime, the more likely the suspect is involved in the suspected or already occurred criminal activity. Here, however, two alleged lookouts to two robberies was not enough. “Looking at the totality of the circumstances, the lookouts, which boiled down to two black men in a white car, at high noon on a weekday, in downtown D.C., were simply insufficient to generate any particularized suspicion that the appellants here were the suspects being sought in connection with the Prince and Whitaker robberies.” Armstrong v. United States, 2017 D.C. App. LEXIS 198 (July 20, 2017).

Defendant’s property was searched by two children and their mother, clearly private actors. United States v. Jordan, 2017 U.S. App. LEXIS 13152 (4th Cir. July 21, 2017).*