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Reasonable Suspicion and Mere Hunches:

My colleague Craig Lerner has a brilliant new piece exploring the implications of modern cognitive science for the idea of "hunches" by experienced police officers and the dilemma they present for the modern police system. As he puts it in the Abstract to his new article "Reasonable Suspicion and Mere Hunches":

In Terry v. Ohio, Earl Warren held that police officers could temporarily detain a suspect, provided that they could articulate the "reasonable inferences" for their suspicion, and not merely allude to a "hunch." Since Terry, the American legal system has discounted the "mere" hunches of police officers, requiring them to articulate "specific" and "objective" observations of fact to support their decision to conduct a stop and frisk. The officer's intuitions, gut feelings and sixth sense about a situation are all disallowed.

This dichotomy between facts and intuitions is built on sand. Emotions and intuitions can be reasonable, and reasons are often predicated on emotions. Even as courts have, over the past two generations, grown more dismissive of hunches, there has been a counter-revolution in the cognitive sciences. Emotions and intuitions are not obstacles to reason, but indispensable heuristic devices that allow people to process diffuse, complex information about their environment and make sense of the world. If the legal rules governing police conduct are premised on a mistaken assumption about human cognition, can one craft a doctrine of policing that credits the wisdom of hunches? Can the legal system defer to police officers' intuitions without undermining protections against law enforcement overreaching?

This article argues that, to some extent, judicial skepticism about police hunches can and should be abandoned. As a practical matter, the current legal regime substitutes palliative euphemisms for useful controls on police discretion. When an energetic police officer has a hunch that something is wrong and action is imperative, the officer will simply act. Months will pass before a suppression hearing, and by then it will be a simple matter to reverse-engineer the objective "reasons" for the stop - e.g., "I saw a bulge." The legal system in practice simply rewards those officers who are able and willing to spin their behavior in a way that satisfies judges, while it penalizes those officers who are less verbally facile or who are transparent about their motivations. It would be preferable if politically accountable authorities joined the courts in monitoring police practices. The focus should be less on what police say after the fact and more on what they do - that is, how successful police officers are in catching criminals and how respectful they are of all citizens.

The point will be familiar to readers of Hayek and Polanyi who draw on the notion of tacit knowledge, and in particular, the notion that much knowledge that derives from experience, tradition, and habit is unarticulated knowledge which is no less valuable or important for being unarticulated or unarticulable. As Lerner notes, the recognition that such knowledge exists places a Court in the position of either excluding this valuable knowledge from the adjudication, or forcing experienced police officers to falsely articulate an untrue explanation for what is fundamentally unarticulated knowledge.

Craig has identified a neat puzzle here.

Update:

Doh--I initially forgot to link to the paper. I've corrected it now.

Related Posts (on one page):

  1. Reasonable Suspicion and the Exclusionary Rule:
  2. Reasonable Suspicion and Mere Hunches:
Paul Gowder (mail) (www):
Do you have a link or cite?
10.12.2005 10:16am
Zywicki (mail):
Paul:
Thanks--I forgot the link. It is fixed now.
10.12.2005 10:45am
Marcus1:
The problem is anyone can say they had a hunch, no? Sure, cops can lie and say there was objective information even when there wasn't, but at least it provides something which can be verified or discredited when cross-examined.

The fact that cops will act anyway where they have a strong hunch (if it's strong, there's probably going to be evidence there anyway), does not discredit the requirement. At least now they know that if they're just sitting around, they're not allowed to detain people just to harass them.
10.12.2005 11:02am
Ken Arromdee (mail):
Marcus: That's exactly it. Anyone can say they had a hunch, and a police officer's "hunch" can be used as cover for inappropriate reasons.

Whether real hunches are reliable is an interesting but ultimately irrelevant digression, since we can't tell between real hunches and excuse-hunches.
10.12.2005 11:38am
MJ (mail):
Totally agree with Ken and Marcus. The problem of allowing "hunches" to be used as evidence of criminal activity is that there is no objective way for a court to evaluate what is a legitimate hunch vs. what was a lucky guess. It then becomes solely a question of the officer's credibility - "Trust me, I really did have a hunch".

At least with the "specific articulable facts" standard you are asking a court to measure against something tangible: objectively, do the facts that the officer is citing as his justification for the stop cause suspicion?

Relying upon a "hunch" as evidence is standardless and unjudiciable.
10.12.2005 11:52am
Bruce Hayden (mail) (www):
I think that that is the real point. What the present law makes the police do is sit there and figure out and articulate why they had the hunch. I think that this has a couple of positive effects.

First, as alluded to above, it cuts down (but obviously does not eliminate) arbitrary searches. It would be so easy to just say, "I had a hunch". I think that it is naive to think that a lot of police don't use their discretion to enforce respect. I have happen to me a couple of times - when I was younger and more in need of the imposition of authority. Nevertheless, I think that it is important that legal limits be placed on this discretion, and legalizing "hunches" would seem to me to give the police one more tool to avoid scrutiny for this.

Secondly, it eliminates some hunches that are based on other that legal basis - such as, for example, that the subject was Black. Yes, maybe the police had a hunch that an African-American dressed in a certain way in a certain area of town is liable to be carrying, for example, illegal drugs. But just because they are more likely to be doing so, doesn't mean that there aren't plenty of law abiding people who would fit that profile.

The problem, as I see it, is that some hunches are based on subconscious information. A lot of this goes on, esp. with experience beat or patrol cops. Years on the street often provide the police who survive them very good instincts.

On the other hand, they also build up stereotypes, and that is not always good. Good in that it makes them more aware for their safety when in certain situations. But bad in that the stereotypes are not always accurate, when applied to specific people.

So, what I think this requirement does is to force the police to try to bring to the surface and articulate what exactly was triggering their interest. Was it that the subject made some suspicious moves? Or just that he was Black?
10.12.2005 11:57am
Andy Freeman (mail):
Shouldn't "probable cause" have a numeric value?

The reason for every search, regardless of result, should be recorded. Reasons that rarely pan out, regardless of how good they sound, should be banned.
10.12.2005 12:01pm
GMUSL 1L (mail):
But bad in that the stereotypes are not always accurate, when applied to specific people.

Bruce -- are stereotypes (or any generalization, for that matter) EVER always accurate?

Obviously not. Then they'd be bright-line rules rather than rebuttable presumptions given the totality of the circumstances.
10.12.2005 12:07pm
Mr. Mandias (mail) (www):
Of course this only comes up when the officer's hunch was justified. If, however, we're talking about letting officers stop 1981 suits on the grounds that they had a hunch, that's absurd.
10.12.2005 12:14pm
Hattio (mail):
"....the notion that much knowledge that derives from experience, tradition, and habit is unarticulated knowledge which is no less valuable or important for being unarticulated or unarticulable."

Others have touched on this above, but as Professor Zywicki notes this tends to be based on experience. In too many large cities this will mean that the officer's experience with certain types of people will be primarily as criminals or suspects. Again this is especially true in large cities where you rarely have to interact with those outside your own social circle. So even "true" hunches are likely to be created by prejudice, whether against a race (African-Americans) or against certain characteristics (men w/long hair).
Finally, another point from the article, he says that what should be focused on is what police do, ie.; how many criminals they catch. It seems to me that this is only focusing on part of what officers do. They exist to serve and protect. If they catch a lot of criminals, but in the process catch a lot of innocents, or even just violate their rights repeatedly, this is also what should be focused on in ascertaining proper police and judicial policy.
10.12.2005 12:42pm
18 USC 1030 (mail):
I think a major problem with legalizing hunches is the way in which different officers would incorporate them into their daily routines. Sure, you have your "good cops" who it by the book and would only stop and harass those whom they actually have a "hunch" about. However, as was mentioned earlier, you have the problem of stereotypes. Many an officer would translate legal hunches as free reign to that which they pleased. For example, officer McClusky sees an african american male dressed in a black hooded jacket at 2am in the inner city. McClusky could walk by and think nothing of it or he may harass him and search him, with the justification being "well....I have seen people in similar situations carrying drugs therefore I had a hunch he was as well." Is this cool? I would have to vote no. Although, this brings up the question again related to terrorism and searches related to terrorist activities.
10.12.2005 1:35pm
Bruce Hayden (mail) (www):
A caller on a local radio station called in one day to complain that he had been pulled over again, for the third or fourth time that year, for Driving While Black. He had been pulled out of traffic all going the same speed on the freeway, maybe 5 miles over the speed limit. Turns out he was driving a BMW, and apparently, a lot of Black drug dealers do the same.

His problem was that he was a single yuppie attorney in a large firm, and a lot of the single yuppie lawyers there drove BMWs. So, he didn't think twice when he bought it.

Was the stop right? I don't think so. But it was more than likely based on the police officer's hunch. The problem though is that his hunch was not based on articulable reasonable suspicions, but rather, on a racial stereotype.

Is there a time for stereotyping by police? Yes, I think so. When the question is that of safety, of keeping heightened awareness, esp. in a vulnerable situation, then I think that it is both natural and justified. So, instead of a traffic stop on a well traveled highway (in this case, the Denver / Boulder turnpike), you have someone dressed like a gang banger in a bad part of town late at night. I think that the cop would be a fool not to watch that guy more closely than a white middle class conservatively dressed and groomed man in the same situation.

The problem comes when this extends to a stop or a search. Then, the rights of the innocent are potentially being infringed, if the stop or search was predicated on a stereotype. And that is why I think that it is important that the police have to articulate their suspiciions before making such a stop or search, but not when they just look at him more carefully. A fine distinction, but I think important.
10.12.2005 1:38pm
Andy Freeman (mail):
> "well....I have seen people in similar situations carrying drugs therefore I had a hunch he was as well." Is this cool? I would have to vote no.

Why doesn't the answer depend on how often such searches have been successful in the past?
10.12.2005 1:41pm
Andy Freeman (mail):
There are alteratives to the record-keeping suggested to make "probable" have some basis. One such alternative is to pay people who are searched a nominal sum, say $20, perhaps regardless of the result of the search.
10.12.2005 1:46pm
roy solomon (mail):
More than anything, of course, this shows how vacuous charges of "sexism" and "elitism" are as substitutes for thinking.

snark>
But it is from experienced people who "have a hunch" /snark>
10.12.2005 2:00pm
Justin (mail):
Also, if hunches excuse searches based on socioeconomic factors, which they invariably will, it will lead to the aggregate criminalization of being poor and black, to an even worse degree than now.

Let's say an African American has an 80% chance of getting randomly stopped for being in the wrong-place wrong-time situation in a given year, whereas a white person has a 0% chance. Let's say that African-Americans and Caucasians are each about the same (say, 35%) of possessing marijuana for recreational use. In the state of Kent, a marijuana conviction leads to, at minimal, a probational sentence and a record, immediate disallowance of educational loans and welfare, and puts one at a significant competitive disadvantage in the job market, with a significant chance of jail time depending on the judge and prosecutor.

While the problem at the first instance is with our drug laws, the cost of the harsh sentences for a recreational event partaken by more than half the population (who possess at, here, 35% of the rate) will disproportionately fall on a political minority. Worse, the use of disenfranchisement law and a general (if ill advised) overemphasis on being tough-on-crime, leads to no political accountability for the harm being done to the minority population of Kent.

The 5th amendment, perhaps unintentionally, acts as a backstop for this. Basically harmless recreational activity such as drug use is rarely enforced because at every level "throw-a-wide-net-and-see-what-you-get" detection is protected by requirements of probable cause combined with choices of police resources. This prevents the power of the state from being manipulated through subconscious arbitrary steroetypes and preferences to damage political minorities. It is unclear what, if anything, will replace that, despite the author's reference to a monitoring system based on "catching criminals".

Finally, on a more substantial political theory note, when we expect people to violate laws (drug laws, traffic laws, sodomy laws, alcohol restrictions, a ton of laws are on the books that are socially acceptable to violate, etc), does the evisceration of the 5th amendment, guarded only by a judgment of "actual innocence", cause any qualms in terms of complete discretion in the prosecutor and police department who gets to suffer the wrath of the state and who does not?
10.12.2005 2:47pm
Hattio (mail):
Justin,
Where is the state of Kent? Are you a Chicago-Kent student/grad?
10.12.2005 3:06pm
Justin (mail):
Hattio, the state of Kent is a fictional state used in legal hypotheticals (see East Dakota). I did not graduate from Chicago-Kent, sorry.
10.12.2005 3:29pm
18 USC 1030 (mail):
Andy,

On a second read, I realize I was not nearly as clear as I should have been. Obviously if the percentage is very high, the search would most likely be ok. However, I would argue that if this was an area where the "success rate" was very high, the officer most likely acted on something other than a hunch. For example, there is a difference between searching any black man you see vs. searching any person matching a description of a possible offender. Also, if someone is walking down the street in a known drug area, it would seem as though the police has some reasonable suscpision as to why the individual was there at 2am. However, if the same individual was walking down a street in a low-crime area, should the police act the same? Should they be allowed to search deeper to inquire why the person is there (i.e. is there a potential break-in)? Should they be restricted in the searches, assuming the person is probably not doing anything wrong?

I remember a time when a buddy of mine and myself were visiting his brother. We were all white middle class driving his father's brand new saab and his brother lived in a shady neighborhood next to the college. His street was pretty safe as it was mostly college kids, but any street leading there had the potential for danger. A cop pulled us over at midnight and asked "why are 2 yuppy white boys driving around here?" "Do you have any drugs in the car? No, oh so you haven't gotten them yet?"

Do I understand why the cop pulled us over? yes

Do I believe he was acting on a hunch? Probably

Do I think he was acting with reasonable cause? No, he had followed us for a while before pulling us over, we had stopped at all lights, signaled, and obeyed the speed limit. In fact, he said as much when he had us pulled over.

So if all he was acting on was a hunch that it didn't seem right that we were there, should he have pulled us over? I have no real problem with it, we did nothing wrong he realized this after a slight inconvenience and let us go. I am not going to try and say my rights were violated, they weren't. I guess it is more of a policy issue, do we want cops pulling people over because of a hunch? I really don't know, I think it'd depend on how inconvient it becomes. If it is what I dealt with, I can deal, if it becomes more intrusive, I may rethink that.
10.12.2005 3:53pm
ras (mail):
If you are interested in the topic of "hunches" you might find food for thought in this online reprint of The Naked Face, a news article. A sample:

It had been raining so much that the sewers in West Hollywood had backed up, and one of the manhole covers had been cordoned off because it was pumping out water. The guy comes over to the squad car, and he's walking right through that. He's fixated on Scott. So we asked him what he was doing. He says, "I was out for a walk.' And then he says, "I have something to show you.'"

Later, after the incident was over, Harms and his partner learned that the man had been going around Hollywood making serious threats, that he was unstable and had just attempted suicide, that he was in all likelihood about to erupt. A departmental inquiry into the incident would affirm that Harms and his partner had been in danger: the man was armed with a makeshift flamethrower, and what he had in mind, evidently, was to turn the inside of the squad car into an inferno. But at the time all Harms had was a hunch, a sense from the situation and the man's behavior and what he glimpsed inside the man's coat and on the man's face-- something that was the opposite of whatever John Yarbrough saw in the face of the boy in Willowbrook. Harms pulled out his gun and shot the man through the open window. "Scott looked at me and was, like, "What did you do?' because he didn't perceive any danger," Harms said. "But I did."
10.12.2005 6:04pm
Andy Freeman (mail):
> On a second read, I realize I was not nearly as clear as I should have been. Obviously if the percentage is very high, the search would most likely be ok. However, I would argue that if this was an area where the "success rate" was very high, the officer most likely acted on something other than a hunch.

High success rate does not imply "not hunch". More important, low success rate does not imply "hunch".

The problem with all of these schemes is that they ignore outcomes and try to guess the appropriate process, which is pretty much guaranteed to fail. The outcomes can be measured and used to control the process.

Of course, I'm assuming that "probable" is supposed to have some connection to search success.
10.12.2005 7:38pm
18 USC 1030 (mail):
> High success rate does not imply "not hunch". More important, low success rate does not imply "hunch".

I agree 100%, I wasn't implying that per se, I was aiming more to say that one would have to look at particular circumstances rather than a statistic. The statistic may show one thing, yet upon further review, it may be totally different. I am sure there are many hunches that are accurate; however, if you have a 100% accuracy in 1 particular location, is this still a hunch; or is this now something more quantifiable? I would say it becomes more reasonable cause than mere hunch.
10.12.2005 7:43pm
Robert Schwartz (mail):
Maybe SCOTUS should get out of the business of running every police department in the country.
10.13.2005 12:15am
Andy Freeman (mail):
I'm confused why the label "hunch" is so important.

Presumably we're not insisting on a causal connection, that we're merely looking for "strong enough" correlation. What MORE must there be?

For example, suppose that the members of particular gang wear a particular model of sneakers and that said gang has traditionally not been in a given section of town. Suddenly there's an increase in crime in said area. If I see someone new to the area running from a new crime scene wearing said sneakers, would I be acting on a hunch?

That's why I advocate measurement. Without measurement, you're just making it up.
10.13.2005 9:53am
18 USC 1030 (mail):
Andy,

With that explanation, I would have to agree with you, the label is unimportant. My question would be what if there wasn't an increase in crime? What if an officer typically in one area is on assignment in another area of the city where similar activity does not occur; if he sees a person walking down the street wearing that model sneaker, is it right for that person to be stopped merely because the officer has a hunch that the shoe is a possible red-flag of criminal activity based on what he has seen in other areas? Of course, this gets into profiling and whether or not it is ever acceptable and if so when. Obviously, the acceptable profiling based on sneakers would be or at least ought, be different in a known gang area than in the suburbs. If an officer is searching for a suspect and the description of that person includes a particular model sneaker, if he stops everyone wearing that shoe, it would be "reasonable." Yet, if he saw a man wearing a particular shoe and stopped him based on the fact that he had arrested someone else at a prior time dressed similarly, this, I believe is a "hunch" and as such should be under more scrutiny than the former example. I guess I am being unrealistically simplistic with my definition of the word "hunch" as compared to reasonableness.
10.13.2005 3:00pm
Fla Prosecutor (mail):
As a prosecutor, I can tell you that it is an absolute necessity to have an objective framework to analyze Terry Stops. In 13 months as a prosecutor, I can't tell you how many cases I've dropped because the cop simply didn't like the person that he pulled over and searched. While most cops are not on "power trips", so to speak, there are still a number of them out there who routinely abuse the system as it stands now, and would leap at the opportunity to continue in their abuse if Terry and its progeny were eroded.
10.13.2005 10:05pm
treefroggy (mail):
Pardon me, but I was under the impression that Hayeks notion of "tacit knowledge" revolved around the issues of
VOLUNTARY commerce and interaction between autonomous individuals and their decision making processes. There is nothing voluntary in the interactions between an agent of the state and a citizen under any of the above situations.

Perhaps we can now start issuing search warrants based solely on inarticulable hunches.
10.13.2005 10:20pm
girls (mail) (www):
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10.25.2005 7:14am
Jonathan Burdick (mail) (www):
Uh ... "brilliant" new piece? WHAT "implications of modern cognitive science"? (didn't find any in the article).

I DESTROYED the recent Lerner article on my ROBOSOLDIERS blog this morning, at:
http: // www.girlrobot.com /blog /2005-10.htm #2005-10-24+13:39:57+1

Thanks for letting me know about it though. I can use the target practice.

/ s /

The Destroyer
11.2.2005 7:18pm
Jonathan Burdick (mail) (www):
Uh ... "brilliant" new piece? WHAT "implications of modern cognitive science"? (didn't find any in the article).

I DESTROYED the recent Lerner article on my ROBOSOLDIERS blog this morning, at:
http: // www.girlrobot.com /blog /2005-10.htm #2005-10-24+13:39:57+1

Thanks for letting me know about it though. I can use the target practice.

/ s /

The Destroyer
11.2.2005 7:18pm
Jonathan Burdick (mail) (www):
Uh ... "brilliant" new piece? WHAT "implications of modern cognitive science"? (didn't find any in the article).

I DESTROYED the recent Lerner article on my ROBOSOLDIERS blog this morning, here.

Thanks for letting me know about it though. I can use the target practice.

/ s /

The Destroyer
11.2.2005 7:19pm
Jonathan Burdick (mail) (www):
I e-mailed Todd Zywicki, and updated my blog post twice.
They still don't get it. The Lerner article is NOT, IMHO, either "thought-provoking" or "brilliant", it's lazy.
Doesn't address the core problem. Traces the Terry case law like a student book report, that's about it.

Zywicki works as a professor at the same law school Lerner does (GMU). It's a case of what we refer to as a Mutual Admiration Society. "Brilliant"? Puhleeeeease ...
Einstein's E = MC2 was "brilliant". A regular old law review article that poses a common problem but offers no solution (other than "we need to hire GOOD cops") is NOT "brilliant". What a bunch of malarkey.
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