Defendant refused to stop when the patrol car\u2019s lights and siren came on, and that was not a seizure until he was actually stopped. His flight was reasonable suspicion, and the movement of his hands in flight added to it. United States v. Rhone, 2012 U.S. Dist. LEXIS 181135 (E.D. Mo. September 19, 2012):<\/p>\n
The Supreme Court has held that presence in an area with a high rate of crime with unprovoked flight can satisfy the reasonable suspicion standard for a Terry stop. Illinois v. Wardlow<\/a>, 528 U.S. 119, 124 (2000). Here, prior to the seizure and search of defendant, the officers found him in the Jeff Vanderlou area, an area with a high rate of crime, and defendant fled from the officers with no provocation. Additionally, while in pursuit of defendant, Officer Anderson observed defendant’s hands moving around his jacket pocket. See United States v. Cornelius, 391 F.3d 965, 968 (8th Cir. 2004) (placing hands in jacket pocket and failure to remove hands upon direction by an officer sufficiently justifies a frisk); United States v. Davis, 202 F.3d 1060, 1063 (8th Cir. 2000) (placing hands in jacket pocket and moving to officer’s backside upon witnessing the frisk of a companion sufficiently justifies a frisk); see also United States v. Roggeman, 279 F.3d 573, 579 (2002) (bulge in the clothing alone can establish a reasonable suspicion).<\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"
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