Last year, Professor Royce Barondes presented an article at a symposium on the 50th Anniversary of Terry v. Ohio. The article examines whether reasonable suspicion a person is armed is, by itself, sufficient to justify a Terry stop.Prof. Barondes concluded not, writing, “[I]t would allow a manifestly unacceptable range of ordinary activity to, by itself, justify Terry stops.” Prof. Barondes noted the approach allowing these stops would, for example, allow police to stop large numbers of persons merely for visiting housing complexes.

In Commonwealth v. Hicks, 208 A.3d 916 (Pa. 2019), the Supreme Court of Pennsylvania concurred with Prof. Barondes’ conclusion, citing his article. In the case, the Supreme Court of Pennsylvania reversed a line of lower-court cases dating to 1991.