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Commonwealth, 72 Va. App. 352, 359 (2020) (quoting Harris v. Commonwealth, 276 Va. 689,
695 (2008)).
Likewise, even though “a suspect’s presence in a high crime area, standing alone, is not
enough to support a reasonable particularized suspicion, it is a relevant contextual consideration
in a Terry analysis.” Whitaker v. Commonwealth, 279 Va. 268, 276 (2010). “But officers are
not required to ignore the relevant characteristics of a location in determining whether the
circumstances are sufficiently suspicious to warrant further investigation.” Illinois v. Wardlow,
528 U.S. 119, 124 (2000). Similarly, “while headlong flight is not necessarily indicative of
wrongdoing, it is a pertinent factor in determining reasonable suspicion.” Whitaker, 279 Va. at
276. Additionally, “nervous, evasive behavior is a pertinent factor in determining reasonable
suspicion.” Wardlow, 528 U.S. at 124.
However, the Fourth Amendment “does prevent the police from stopping and frisking
individuals in the absence of ‘reasonable suspicion’ that the individual has committed, or is
about to commit, a crime.” Northrup v. City of Toledo Police Dep’t, 785 F.3d 1128, 1131 (6th
Cir. 2015) (quoting Terry, 392 U.S. at 27). Indeed, “[m]ore than an ‘inchoate and
unparticularized suspicion or “hunch”’ is needed to stop and frisk an individual.” Id. (quoting
Terry, 392 U.S. at 27). Rather, “the officer must identify ‘specific and articulable facts’ of
criminality.” Id. (quoting Terry, 392 U.S. at 27). “Although a mere hunch does not create
reasonable suspicion, the level of suspicion the standard requires is considerably less than proof
of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for
probable cause.” Mitchell, 73 Va. App. at 246-47 (quoting Bland, 66 Va. App. at 413).
Instead, reasonable suspicion “requires only ‘some minimal level of objective
justification.’” Williams, 71 Va. App. at 482 (quoting Hairston v. Commonwealth, 67 Va. App.
552, 561 (2017)). Thus, when “evaluating whether an investigative detention is unreasonable,
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