State v. Guzy
In State v. Guzy, 139 Wis. 2d 663, 407 N.W.2d 548 (1987), the Court recognized that the mere "incantation of the traditional test for investigatory stops-'specific and articulable facts'-at times provides little guidance for courts ... in determining the quantum and nature of information necessary to establish the reasonableness of the stop." Id. at 676.
To assist in making this determination, the court employed six factors:
(1) the particularity of the description of the offender ...;
(2) the size of the area in which the offender might be found, as indicated by such facts as the elapsed time since the crime occurred;
(3) the number of persons about in that area;
(4) the known or probable direction of the offender's flight;
(5) observed activity by the particular person stopped;
(6) knowledge or suspicion that the person ... stopped has been involved in other criminality of the type presently under investigation. (139 Wis. 2d at 676-77.)
Recognizing that some of the factors may not be applicable, the court concluded that an accurate application of these factors requires courts to analyze them in conjunction with "the facts and circumstances present" in each case. Id. at 677 (recognizing the difficulty inherent in determining the number of facts that must be present, the weight to be given to each fact, and the point at which the presence of one fact or another crosses the line from hunch to reasonable suspicion).