What facts support reasonable suspicion for a police officer to detain two people in a car after receiving a report of a burglary?

California, United States of America


The following excerpt is from People v. Rodriguez, B280981 (Cal. App. 2017):

Indeed, there are more facts here to support reasonable suspicion than were found adequate in People v. Conway (1994) 25 Cal.App.4th 385. There, the detaining officer had received a report of a burglary in progress in the neighborhood he was patrolling, but had no description of the suspects and did not know if they were in a car. Nevertheless, the court found that the officer's detention of two individuals in a car was justified, explaining as follows: "Less than two minutes after receiving the report of a burglary in progress, he saw a car leaving the area of the reported burglary. The time was approximately 3 a.m., and the officer saw no one else in the area. Under the circumstances, it was objectively reasonable for the officer to suspect the car's occupants were involved in the burglary. [Citations.] [] We recognize that driving in a residential area early in the morning

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