In Illinois v. Wardlow, 528 U.S. 119, (2000), police in a high-crime area observed the defendant standing in the shadow of a building holding an opaque bag. (Id. at pp. 121-122.) The defendant looked in the officers' direction, then fled. (Id. at p. 122.) Officers apprehended the defendant and conducted a protective search that revealed a handgun and live rounds hidden in his bag. (Ibid.) The Supreme Court held that the detention that uncovered the gun was supported by reasonable suspicion. (Id. at p. 125.) The Court explained that flight, as "the consummate act of evasion," is "certainly suggestive" of criminal wrongdoing. (Id. at p. 124.) It added that where conduct is ambiguous and equally susceptible to a criminal or innocent explanation, police may detain suspicious individuals to resolve the ambiguity. (Ibid.) In Illinois v. Wardlow, two officers were driving in an area known for heavy narcotics trafficking. Id. at 121, 120 S. Ct. at 674. One of the officers observed Wardlow standing next to a building holding an opaque bag. Id. at 121-22, 120 S. Ct. at 674-75. Wardlow looked at the officers and fled. Id. at 122, 120 S. Ct. at 675. The officers pursued Wardlow in their car, and eventually cornered him on the street. Id. One of the officers exited the car and stopped Wardlow. Id. The officer frisked Wardlow's bag for weapons, discovered a handgun, and arrested him. Id. In sum, a four-police-car caravan converged in an area known for heavy narcotics trafficking. An officer in the fourth car observed the defendant standing next to a building holding an opaque bag. The defendant looked in the officer's direction, then ran through a gangway and alley. The officer, in his car, eventually cornered the defendant on the street, exited his car, detained the defendant, and found a handgun and ammunition during a patdown. ( Id. at pp. 122-123 120 S. Ct. at pp. 675-676.) Wardlow concluded that, although "flight is not necessarily indicative of ongoing criminal activity," the officer was justified in suspecting defendant's involvement in criminal activity based on the entire context of his "unprovoked" "headlong" flight. ( Id. at pp. 125, 126 120 S. Ct. at pp. 676, 677.) As Wardlow observed, when an officer, without reasonable suspicion, approaches an individual, the individual has the right to ignore the police and go about his business. "Any 'refusal to cooperate, without more, does not furnish the minimal level of objective justification needed for a detention . . . ." ( Id. at p. 125 120 S. Ct. at p. 676.) The United States Supreme Court held the defendant's presence in an area known for drug activity and "his unprovoked flight upon noticing the police" provided reasonable suspicion for the detention. (Wardlow, supra, 528 U.S at p. 124.) The court distinguished a defendant's "unprovoked flight" from a defendant's refusal to cooperate, noting that a defendant's mere "'refusal to cooperate, without more, does not furnish the minimal level of objective justification needed for a detention or seizure.'" (Id. at p. 125)The United States Supreme Court noted: "Our cases have also recognized that nervous, evasive behavior is a pertinent factor in determining reasonable suspicion. Headlong flight -- wherever it occurs -- is the consummate act of evasion: It is not necessarily indicative of wrongdoing, but it is certainly suggestive of such. In reviewing the propriety of an officer's conduct, courts do not have available empirical studies dealing with inferences drawn from suspicious behavior, and we cannot reasonably demand scientific certainty from judges or law enforcement officers where none exists. Thus, the determination of reasonable suspicion must be based on commonsense judgments and inferences about human behavior." Id. at 124. The United States Supreme Court held that police knowledge of an area as a high crime area and flight by a suspect were enough to raise a reasonable and articulable suspicion. In Wardlow, the defendant fled when he saw police vehicles converge on an area that was known for heavy drug trafficking. Id. Two police officers stopped the defendant, and one of them conducted a protective patdown search for weapons because the officer, on the basis of his experience, believed that there were usually weapons in the vicinity of drug transactions. Id., 675. The Illinois Supreme Court affirmed the appellate court's reversal of Wardlow's subsequent conviction on grounds the police did not have reasonable suspicion to stop him. Id. The United States Supreme Court reversed the Illinois Supreme Court's decision, and held there was reasonable suspicion to justify the stop. Id. at 123-25, 120 S. Ct. at 675-76. The Court reasoned the defendant's presence in a high crime area, in combination with his unprovoked flight from the police, was sufficient to establish reasonable suspicion. Id. The Court stated "nervous, evasive behavior is a pertinent factor in determining reasonable suspicion." Id. at 124, 120 S. Ct. at 676. In Illinois v. Wardlow, police officers were "converging on an area known for heavy narcotics trafficking in order to investigate drug transactions" when the officers "observed . . . Wardlow standing next to a building holding an opaque bag." Wardlow, 528 U.S. at 121-22. The officers seized Wardlow after he "looked in the direction of the officers and fled." Id. at 122. The Supreme Court held that the officers articulated a reasonable suspicion that Wardlow was engaged in criminal activity because of his "presence in an area of heavy narcotics trafficking," the usual presence of drug sellers and lookouts, and "his unprovoked flight upon noticing the police." Id. at 124. It is this series of acts that gave rise to a reasonable suspicion of criminal conduct in Wardlow. The Supreme Court concluded that such circumstances gave rise to reasonable suspicion Wardlow was engaged in criminal activity and justified a related detention. Id. at 124. The United States Supreme Court upheld a search and seizure involving illegal drugs based upon all the facts and attendant circumstances shown in that case. In Wardlow, the United States Supreme Court stated the facts as follows: "On September 9, 1995, Officers Nolan and Harvey were working as uniformed officers in the special operations section of the Chicago Police Department. The officers were driving the last car of a four car caravan converging on an area known for heavy narcotics trafficking in order to investigate drug transactions. The officers were traveling together because they expected to find a crowd of people in the area, including lookouts and customers. "As the caravan passed 4035 West Van Buren, Officer Nolan observed respondent Wardlow standing next to the building holding an opaque bag. Respondent looked in the direction of the officers and fled. Nolan and Harvey turned their car southbound, watched him as he ran through the gangway and an alley, and eventually cornered him on the street. Nolan then exited his car and stopped respondent. He immediately conducted a protective pat-down search for weapons because in his experience it was common for there to be weapons in the near vicinity of narcotics transactions. During the frisk, Officer Nolan squeezed the bag respondent was carrying and felt a heavy, hard object similar to the shape of a gun. The officer then opened the bag and discovered a .38-caliber handgun with five live rounds of ammunition. The officers arrested Wardlow." 528 U.S. at 121-122, 120 S. Ct. at 674-75. The issue in Wardlow was whether Officer Nolan was justified in conducting a stop-and-frisk search of Wardlow under Terry v. Ohio, 392 U.S. 1 (1968). The United States Supreme Court determined that he was.