Coleman v. State

In Coleman v. State, 553 P.2d 40 (Alaska 1976), the Alaska Supreme Court was asked to decide whether the Alaska Constitution permits a police officer to conduct an investigative stop based on reasonable suspicion (i.e., less than probable cause). The court ruled that investigative stops based on reasonable suspicion are permitted in two instances: when the officer has reason to believe that "imminent public danger exists", or when the officer has reason to believe that "serious harm to persons or property has recently occurred". The Court held that not every reasonable suspicion of criminal activity will justify an investigative stop under the Alaska Constitution. Rather, investigative stops are limited to situations where the police have "reasonable suspicion that imminent public danger exists or that serious harm to persons or property has recently occurred". Coleman, 553 P.2d at 46.