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Sokolow v. United States

Facts

DEA agents in Honolulu observed Andrew Sokolow purchasing two round-trip airline tickets to Miami for $2,100 in cash, using a roll of $20 bills. He traveled under an alias, appeared nervous, and did not check any luggage. Upon his return to Honolulu, DEA agents stopped him and found cocaine in his luggage after a dog alerted to its presence. Sokolow entered a conditional guilty plea, but the Ninth Circuit reversed his conviction, stating the agents lacked reasonable suspicion.

Respondent Andrew Sokolow was stopped by Drug Enforcement Administration (DEA) agents upon his arrival at Honolulu International Airport. The agents found 1,063 grams of cocaine in his carry-on luggage. When respondent was stopped, the agents knew, inter alia, that (1) he paid $2,100 for two airplane tickets from a roll of $20 bills; (2) he traveled under a name that did not match the name under which his telephone number was listed; (3) his original destination was Miami, a source city for illicit drugs; (4) he stayed in Miami for only 48 hours, even though a round-trip flight from Honolulu to Miami takes 20 hours; (5) he appeared nervous during his trip; and (6) he checked none of his luggage.

Issue

Did the DEA agents have reasonable suspicion to stop Andrew Sokolow based on the totality of the circumstances?

Did the DEA agents have reasonable suspicion to stop Andrew Sokolow based on the totality of the circumstances?

Rule

The police can stop and briefly detain a person for investigative purposes if the officer has a reasonable suspicion supported by articulable facts that criminal activity may be afoot, even if the officer lacks probable cause.

In Terry v. Ohio, 392 U.S. 1, 30 (1968), we held that the police can stop and briefly detain a person for investigative purposes if the officer has a reasonable suspicion supported by articulable facts that criminal activity 'may be afoot,' even if the officer lacks probable cause.

Analysis

The Supreme Court determined that while each of Sokolow's actions could be interpreted as innocent, the combination of factorssuch as the cash purchase of tickets, the short duration of his trip to a known drug source, his nervous demeanor, and the use of an aliascreated a reasonable suspicion that he was involved in drug trafficking. The Court emphasized the importance of considering the totality of the circumstances rather than isolating individual actions.

We think the Court of Appeals' effort to refine and elaborate the requirements of 'reasonable suspicion' in this case creates unnecessary difficulty in dealing with one of the relatively simple concepts embodied in the Fourth Amendment. In evaluating the validity of a stop such as this, we must consider 'the totality of the circumstances — the whole picture.' United States v. Cortez, 449 U.S. 411, 417 (1981).

Conclusion

The Supreme Court reversed the Ninth Circuit's decision, holding that the DEA agents had reasonable suspicion to stop Sokolow, thus reinstating his conviction.

We now reverse.

Who won?

The United States prevailed in the case, as the Supreme Court found that the DEA agents had reasonable suspicion based on the totality of the circumstances surrounding Sokolow's behavior.

The United States prevailed in the case, as the Supreme Court found that the DEA agents had reasonable suspicion based on the totality of the circumstances surrounding Sokolow's behavior.

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