In re K.P.

The D.C. Court of Appeals reversed a decision of the D.C. Superior Court in a case considering whether police responding to a 911 call that reported armed threats had enough information to justify stopping a group of juveniles including the defendant, one of whom ?but without knowing which?they suspected of making the threats. On appeal, the defendant argued that the trial court?s finding of a sufficient link between the group that accosted the complainant and the group seized was erroneous because no record evidence supported an inference that the police had received information particularized even as to the group?much less the defendant?enough to justify the stop under Terry v. Ohio (1968). The appeals court agreed, noting that what information precisely the complainant conveyed to the police dispatcher in her 911 call was unknown because the recorded call was not introduced into evidence. The court added that even the government recognized at oral argument that the record of what the police learned from the complainant was thin, and in the court?s view, it was too insubstantial to demonstrate the reasonable, articulable suspicion required by Terry v. Ohio.