State v. Fornof
In State v. Fornof, 218 Ariz. 74, 76, P 5, 179 P.3d 954, 956 (App. 2008), an officer observed a pedestrian exchange unknown items with a passenger in a car, late at night, at an intersection known for high levels of drug-related activity. 218 Ariz. at 75, 77, PP 2, 9, 179 P.3d at 955, 957.
When the pedestrian saw the police officer's car approaching, he walked away quickly. Id. at 75, P 2, 179 P.3d at 955.
The car then drove away and the police followed. Id. The officer eventually stopped the car and, after further investigation, arrested one of the passengers. Id.
The Court affirmed the superior court's denial of the defendant's motion to suppress. Id. at 79, PP 18-19, 179 P.3d at 959.
The Court noted each of the facts, in isolation, may have been susceptible to an innocent explanation, but when considered together were sufficient to establish reasonable suspicion. Id.
The Court also noted factors such as the time of day, a high crime area, and "a suspect's hasty departure from the scene, although falling short of flight, may further support an officer's reasonable suspicion." Id. at 78-79, P 17, 179 P.3d at 958-59.