Reid v. Georgia

In Reid v. Georgia, 448 U.S. 438, 100 S. Ct. 2752, 65 L. Ed. 2d 890 (1980), a Drug Enforcement Administration (DEA) agent stopped Reid outside a Georgia airport because he had: (1) arrived from Fort Lauderdale, which the agent described as "a principal place of origin of cocaine"; (2) arrived early in the morning, "when law enforcement activity is diminished"; (3) walked in front of another person and occasionally looked back at him as the two walked through the airport; and; (4) "they apparently had no luggage other than their shoulder bags." Id. The Court concluded the agent had lacked reasonable suspicion for the stop because only two of the four factors related to Reid's "particular conduct" and the other factors "describe a very large category of presumably innocent travelers, who would be subject to virtually random seizures were the Court to conclude that as little foundation as there was in this case could justify a seizure." Id. at 441. But, the Court's admonition did not create a new standard for determining reasonable suspicion. Indeed, the Court noted that "although there could, of course, be circumstances in which wholly lawful conduct might justify the suspicion that criminal activity was afoot, this is not such a case." Id.