Reasonable Suspicion Without Known Warrants: United States v. Htoo and the Totality of Circumstances in Gang-Context Stops

I. Introduction

United States v. Htoo, No. 24-1387 (10th Cir. Dec. 10, 2025), is a non‑precedential order and judgment from the Tenth Circuit that nonetheless offers a detailed and instructive application of the Fourth Amendment reasonable‑suspicion standard in a contemporary urban gang‑policing context.

The case addresses whether Denver gang‑unit officers had reasonable suspicion to conduct an investigative detention—a so‑called Terry stop—of September Htoo, where the officers:

• Encountered him walking with a known gang member and homicide person-of-interest,
• Observed both men in a high‑crime area associated with a rival gang’s territory,
• Saw the men run when officers turned their car around, and
• Observed what they described as the imprint of a gun under Htoo’s shirt while he held his waistband as he fled.

After being detained, Htoo voluntarily stated he had a gun, which officers seized. He was later charged with possession of a firearm as a felon. He moved to suppress:

• His statement about possessing the firearm, and
• Evidence of the firearm itself,

arguing that the detention violated the Fourth Amendment because the officers allegedly:

• Did not actually recognize him as a person with outstanding warrants, and
• Lacked independent reasonable suspicion of criminal activity.

The district court denied the motion to suppress; Htoo appealed. The Tenth Circuit affirmed, holding that the officers had reasonable suspicion to detain him even independent of any knowledge of his identity or warrant status.

Although the panel explicitly notes that this order and judgment is not binding precedent (except in limited doctrines such as law of the case, res judicata, and collateral estoppel), it may be cited for persuasive value. Practically, it refines how the totality of the circumstances test applies in gang‑unit policing, especially when:

• The suspect is associated with a known gang member,
• The encounter occurs in a high‑crime area,
• The suspect initially flees, and
• There is evidence suggestive of a concealed firearm.

II. Summary of the Opinion

A. Factual Background

Officers Andrew Niccum and John Wickiser were working with Denver’s Placed Network Investigations Unit, a specialized gang‑focused unit that frequently patrols the area near East Colfax Avenue, described as a high‑crime area.

While on patrol, the officers saw two men walking toward them. They recognized one as She Ler Yer Lee, identified in the opinion as:

• A known gang member, and
• A person of interest in a homicide investigation, with outstanding warrants.

When the officers turned their car around to get a better look at the two men, both Htoo and Lee began to run. The officers activated their body‑worn cameras and pursued. Officer Wickiser caught up with Htoo, grabbed him, and placed him in handcuffs, which all parties agree constituted a seizure (an investigative detention).

During this detention:

• Htoo voluntarily stated that he had a gun.
• Officer Niccum responded, “I know you got a gun, bro.”
• Niccum, who had previously arrested Htoo, asked repeatedly for his name.
• After Htoo provided his name, Niccum referenced his belief that Htoo had felony warrants (“I know he has a felony robbery, I think. Or probation violation or something like that.”).
• The officers retrieved a firearm from Htoo’s waistband.
• A record check confirmed that Htoo had multiple outstanding warrants, including for probation violation.

Based on these events, officers arrested Htoo for:

• Being a felon in possession of a firearm, and
• The outstanding warrants.

B. Procedural History

Before trial, Htoo filed a motion to suppress both:

• His statement that he had a gun, and
• The firearm itself as evidence.

He argued that:

• The officers did not, in fact, recognize him at the time of the detention,
• They therefore did not know he had outstanding warrants, and
• Independent of any such knowledge, they lacked reasonable suspicion to detain him under the Fourth Amendment.

The district court held a suppression hearing, received testimony from both officers, and reviewed the body‑worn camera footage. The court found that:

• The officers had at least a “strong suspicion” that the man they were detaining was Htoo and that he had active warrants.
• Even apart from the warrant issue, several facts together established reasonable suspicion for an investigative detention:
• Htoo was walking with Lee, a known gang member and homicide subject,
• They were in a high‑crime area that was rival‑gang territory,
• They appeared hypervigilant (“heads were on a swivel”), and
• They ran when officers turned around, during which officers saw:
  • The imprint of a gun under Htoo’s shirt, and
  • Htoo holding his waistband as if securing a weapon.

Based on the totality of the circumstances, the district court denied the motion to suppress. Htoo appealed to the Tenth Circuit. Jurisdiction arose under 28 U.S.C. § 1291.

C. Issues on Appeal

Htoo challenged the denial of his suppression motion on two grounds:

1. The district court clearly erred in finding that the officers had a “strong suspicion” that the man they detained was Htoo and that he had active warrants.
2. Even if the officers did not know his identity or warrant status, they lacked independent reasonable suspicion to conduct a warrantless investigatory detention.

The Tenth Circuit resolved the case on the second issue alone. It held that, even assuming the officers did not actually know who Htoo was or that he had warrants, the combination of circumstances provided reasonable suspicion for the stop. Because that determination alone sufficed, the panel explicitly declined to reach the question of whether the officers had a “strong suspicion” he was subject to warrants.

D. Holding

The Tenth Circuit affirmed the district court’s denial of the motion to suppress. The panel held that under the totality of the circumstances, the officers had an objectively reasonable, articulable suspicion that criminal activity was afoot, where:

• The officers:
  • Saw Htoo with a known gang member and wanted person,
  • Observed both men in a high‑crime area that was rival gang territory,
  • Observed flight when they turned their vehicle around, and
  • Observed both:
    • The imprint of a firearm under Htoo’s shirt, and
    • His grasping of his waistband while running.
• These facts, considered together, satisfied the “not onerous” reasonable‑suspicion standard.

Thus, the investigatory detention did not violate the Fourth Amendment, and the evidence obtained following that stop—including Htoo’s admission and the firearm—was not subject to suppression.

III. Precedents and Authorities Cited

The opinion is heavily rooted in established Supreme Court and Tenth Circuit doctrine. It uses prior cases to:

• Define reasonable suspicion,
• Explain the standard of review,
• Clarify the significance of factors like high‑crime areas, flight, and association with known criminals, and
• Support deference to the credibility findings of the district court.

A. Standard of Review and Appellate Posture

• United States v. Canada, 76 F.4th 1304 (10th Cir. 2023) Used to restate the framework for reviewing denial of a suppression motion:
  • The court looks at the totality of the circumstances.
  • It views the evidence in the light most favorable to the government.
  • It accepts the district court’s factual findings unless clearly erroneous.
  • It reviews de novo the ultimate legal conclusion of reasonableness under the Fourth Amendment.
• United States v. Dennison, 410 F.3d 1203 (10th Cir. 2005) Cited for:
  • The standard of review, and
  • The “common purpose or enterprise” inference in vehicle stops, where the presence of one suspect with a known fugitive can inform reasonable suspicion as to other occupants.
  The Htoo panel explicitly declines to decide whether that inference should be extended beyond the vehicle context.
• United States v. Windom, 863 F.3d 1322 (10th Cir. 2017) Quoted to reinforce that the district court’s ultimate Fourth Amendment determination is reviewed de novo.
• United States v. Hernandez, 847 F.3d 1257 (10th Cir. 2017) Cited for the definition of clear error: a factual finding is clearly erroneous if unsupported by the record or if the reviewing court has a “definite and firm conviction that a mistake has been made.”

B. Terry Stops and Reasonable Suspicion

• Terry v. Ohio, 392 U.S. 1 (1968) The foundational case establishing that police may briefly detain a person for investigative purposes if they have reasonable suspicion that criminal activity may be afoot, even without probable cause to arrest.
• United States v. Espinosa, 782 F.2d 888 (10th Cir. 1986) Clarifies that an investigative detention is itself a “seizure” within the meaning of the Fourth Amendment.
• United States v. King, 990 F.2d 1552 (10th Cir. 1993) States that a stop is lawful at its inception when an officer has “articulable and reasonable suspicion that the person detained is engaged in criminal activity.”
• United States v. Sokolow, 490 U.S. 1 (1989) Often cited for two key ideas:
  • Reasonable suspicion is evaluated under the totality of the circumstances, and
  • Courts must avoid a “divide‑and‑conquer analysis” in which individual factors are discounted when viewed in isolation.
  Htoo draws on this cumulative approach, rejecting the defense’s attempt to attack each factor separately.
• United States v. Cortez, 449 U.S. 411 (1981) Emphasizes that reasonable suspicion requires a “particularized and objective basis” for suspecting criminal activity, derived from the totality of the circumstances.
• United States v. Pettit, 785 F.3d 1374 (10th Cir. 2015) Reiterates the Cortez standard and describes reasonable suspicion as “not an onerous” standard.
• United States v. Kitchell, 653 F.3d 1206 (10th Cir. 2011) Quoted in Pettit, underscoring that the bar for reasonable suspicion is relatively low compared to probable cause.
• United States v. McHugh, 639 F.3d 1250 (10th Cir. 2011), and United States v. Lopez, 518 F.3d 790 (10th Cir. 2008) Clarify that the level of suspicion for a Terry stop is “considerably less” than that required for probable cause or a preponderance of the evidence.
• United States v. Salazar, 609 F.3d 1059 (10th Cir. 2010), and United States v. Zubia-Melendez, 263 F.3d 1155 (10th Cir. 2001) Stress that courts must not isolate each fact but must instead consider all circumstances together. They also justify deference to a trained officer’s ability to discern suspicious from innocent behavior.

C. High‑Crime Areas, Flight, and Association with Criminals

• Illinois v. Wardlow, 528 U.S. 119 (2000) Central to the Htoo opinion, Wardlow holds:
  • Presence in a high‑crime area is a relevant factor—though not enough by itself—to support reasonable suspicion.
  • “Headlong flight” is “the consummate act of evasion,” suggestive of wrongdoing (though not conclusively proving it).
  Htoo quotes and applies these principles to uphold consideration of:
  • The East Colfax corridor as a high‑crime area, and
  • Htoo’s initial flight upon seeing officers reverse their vehicle.
• United States v. Guardado, 699 F.3d 1220 (10th Cir. 2012), and United States v. Garcia, 459 F.3d 1059 (10th Cir. 2006) These cases:
  • Recognize that presence in a high‑crime area alone does not establish reasonable suspicion.
  • Allow that being in a high‑crime area is a relevant contextual factor within the totality analysis.
  • Support that association with known criminals (such as a known gang member) can bolster suspicion when combined with other facts.
  Htoo relies on this line of cases to:
  • Refuse to discard the “high‑crime area” factor despite concerns that it can act as a proxy for race or ethnicity, and
  • Emphasize that Lee’s status as a known gang member is relevant but not dispositive alone.

D. Firearms as a Contributing Factor

• United States v. Young, 99 F.4th 1136 (10th Cir. 2023) Cited to support the principle that possession of a firearm, when considered with other facts, can contribute to reasonable suspicion. The Htoo panel invokes Young to justify giving weight to:
  • The imprint of a weapon under Htoo’s shirt, and
  • His grasping of his waistband while running, which officers interpreted as holding a firearm in place.

E. Credibility and Deference to the District Court

• United States v. Asch, 207 F.3d 1238 (10th Cir. 2000), and Anderson v. Bessemer City, 470 U.S. 564 (1985) These cases caution appellate courts against second‑guessing trial courts’ credibility determinations. In Htoo, the defendant argued that officers’ testimony about seeing the gun’s imprint and waistband‑holding was suspect because:
  • Those observations were not in their written reports, and
  • They were not explicitly narrated on the body‑cam footage.
  The Tenth Circuit, citing Asch and Anderson, refused to disturb the district court’s credibility finding where:
  • The body‑cam did not contradict the officers’ claims, and
  • The officers’ statements were partly corroborated by Niccum’s immediate response, “I know you got a gun, bro.”

IV. Legal Reasoning and Application

A. Core Legal Question

The central legal issue was whether the officers had reasonable suspicion to conduct a warrantless investigative detention of Htoo under the Fourth Amendment, even if they did not actually know he had outstanding warrants at the time of the stop.

In Fourth Amendment terms, the question is whether a reasonable, trained officer in the same position, and knowing what Niccum and Wickiser knew at the moment they seized Htoo, would have had a particularized and objective basis to suspect criminal activity was afoot.

B. The Four Key Factors in the Totality Analysis

The Tenth Circuit identifies and analyzes four central facts that, together, support reasonable suspicion:

1. Association with a Known Gang Member and Homicide Subject (Lee) The officers positively identified Lee as:
   • A known gang member, and
   • A person of interest in a homicide investigation with warrants.
   This association is not enough, standing alone, to justify a stop of everyone in Lee’s vicinity. However, Htoo was:
   • Not merely in the vicinity of Lee, but walking with him,
   • In an area of rival gang territory, and
   • Engaging in additional suspicious behavior (hypervigilance and flight).
   Prior Tenth Circuit cases (e.g., Guardado, Garcia) support the proposition that association with known criminals may bolster reasonable suspicion when combined with other suspicious circumstances.
2. Presence in a High‑Crime Area (Rival Gang Territory) The opinion acknowledges that:
   • Being in a high‑crime area cannot by itself establish reasonable suspicion, and
   • There are legitimate concerns that “high‑crime area” can act as a proxy for race or ethnicity.
   Nonetheless, following Wardlow, the court treats the high‑crime character of the location as a relevant contextual factor in the totality analysis. Here, the area was:
   • Known rival gang territory, and
   • A focus of a specialized gang‑investigation unit,
   which the court treats as lending weight to the officers’ inferences about criminal activity when combined with the other facts.
3. Flight Upon Police Attention When the officers turned their car around to get a closer look at Htoo and Lee, both men ran. The opinion, relying on Wardlow, describes “headlong flight” as:
   • Not necessarily proof of wrongdoing, but
   • Strongly suggestive of it, and a valid component of reasonable suspicion.
   Htoo argued that his eventual return to a walk by the time Wickiser caught up to him should diminish the significance of his initial flight. The court rejects this:
   • The initial flight itself is what matters for reasonable suspicion.
   • Ceasing to run as officers are closing in does not “erase” the inference of evasion created by the earlier conduct.
4. Evidence Suggestive of a Firearm (Imprint and Waistband Holding) The officers testified that:
   • They saw the imprint of a gun under Htoo’s shirt while he ran, and
   • He was holding his waistband as if keeping a weapon in place.
   Htoo challenged this testimony on credibility grounds because:
   • These details were not in the officers’ written reports.
   • They were not discussed on the body‑cam footage.
   The Tenth Circuit:
   • Relies on Asch and Anderson to affirm the district court’s credibility finding.
   • Notes that the body‑cam footage does not contradict the officers’ description and may partially corroborate it (given Niccum’s immediate remark, “I know you got a gun, bro”).
   • Invokes Young to confirm that possible or apparent firearm possession can contribute to reasonable suspicion in combination with other factors.

C. Rejecting the “Divide-and-Conquer” Approach

A key aspect of the court’s reasoning is its insistence on the totality-of-the-circumstances approach. Htoo’s appellate arguments tried to minimize each factor in isolation:

• Association with a gang member is not enough;
• High‑crime area status is problematic and non‑dispositive;
• Flight alone is not proof of wrongdoing;
• Apparent possession of a firearm can be innocent in some contexts;
• The officers’ credibility should be doubted because of omissions in paperwork.

The Tenth Circuit responds by emphasizing that the proper question is not whether any single one of these facts would suffice, but whether, taken together, they create a particularized, objective basis to suspect criminal activity. In doing so it follows:

• Sokolow and Cortez (rejecting divide‑and‑conquer parsing),
• McHugh, Lopez, and Pettit (reasonable suspicion is a lower threshold), and
• Zubia-Melendez and Salazar (deference to officer’s trained assessment of behavior in context).

Applying that framework, the panel concludes that the convergence of:

• Gang association with a known and wanted individual,
• High‑crime, rival‑gang territory,
• Hypervigilant behavior (“heads on a swivel”),
• Flight upon noticing police scrutiny, and
• Evidence suggestive of a concealed firearm,

is more than sufficient under the “not onerous” reasonable suspicion standard.

D. The Unresolved “Common Purpose / Enterprise” Extension

The defense argued that the district court improperly extended the “common purpose or enterprise” inference from the vehicle context (as in Dennison) to pedestrians. That inference allows officers to suspect that passengers in a car may be engaged in a shared criminal enterprise, especially where one is already suspected or known to have warrants.

The Tenth Circuit carefully sidesteps deciding whether the Dennison inference should apply to individuals outside the vehicle context. It notes:

• In Dennison, the inference helped establish reasonable suspicion when a passenger was with a wanted fugitive in a car.
• In Htoo, the district court did not treat association with Lee as dispositive, but only as one factor among many.

The panel therefore:

• Affirms that association with a known gang member is a relevant factor,
• Declines to extend or reject the vehicle‑based enterprise inference to street encounters, and
• Explicitly says it does not address whether to expand that doctrine.

This leaves an open doctrinal question for future cases:

To what extent can officers infer a “common criminal purpose” among people associating on foot from the known criminality of one member of the group, absent a vehicle context?

E. Avoiding the Warrant‑Recognition Question

Htoo’s first appellate argument was that the district court clearly erred in finding the officers had a “strong suspicion” that the person they detained was, in fact, September Htoo with active warrants. That issue raises potentially difficult factual and legal questions about:

• How certain officers must be about a suspect’s identity to rely on outstanding warrants, and
• What level of mistaken identity is permissible under the Fourth Amendment.

The Tenth Circuit avoids these complications. It explicitly states that because it finds independent reasonable suspicion based on the gang, location, flight, and firearm‑imprint factors, it need not and does not decide the warrant‑recognition issue. This is analytically conservative:

• The court resolves the case on narrow grounds strongly supported by precedent.
• It leaves for another day any potential rule about how much certainty is required before officers may detain based on suspected warrants.

V. Complex Concepts Simplified

A. Reasonable Suspicion vs. Probable Cause

These two standards are central to Fourth Amendment law:

• Probable Cause This is a higher standard, required for:
  • Arrests, and
  • Most searches (absent an exception, such as consent or exigent circumstances).
  It means there is a “fair probability” that a crime has been committed and that the person or place searched is connected to the crime.
• Reasonable Suspicion A lower standard, required for:
  • Brief investigative stops (Terry stops), and
  • Limited pat‑downs for weapons when there is suspicion the suspect is armed and dangerous.
  It requires more than a “hunch” but less than probable cause. Officers must be able to articulate specific facts, viewed in context, that would make a reasonable officer think criminal activity might be occurring.

In Htoo, the court repeatedly emphasizes that reasonable suspicion is “not an onerous” standard and is “considerably less” than probable cause. The question is not whether the officers were right, but whether their inferences were reasonable at the time.

B. Terry Stop / Investigative Detention

A Terry stop (or investigative detention):

• Is a brief, on‑the‑spot detention for questioning or investigation.
• Requires reasonable suspicion of criminal activity, not probable cause.
• Is considered a “seizure” under the Fourth Amendment.
• May be accompanied by:
  • Measures like handcuffing or drawing weapons, if reasonably necessary for officer safety or to prevent flight, though such measures can sometimes push the encounter closer to an arrest.

Htoo does not hinge on whether the stop ripened into an arrest at some point; the key is whether the initial seizure (when Wickiser grabbed and cuffed him) was justified by reasonable suspicion.

C. Motion to Suppress and the Exclusionary Rule

A motion to suppress asks the court to exclude evidence from trial because it was obtained in violation of the Constitution (here, the Fourth Amendment). If the initial stop is unconstitutional:

• Any statements made during the unlawful detention, and
• Physical evidence discovered (such as the firearm),

may be deemed the “fruit of the poisonous tree” and excluded under the exclusionary rule.

In Htoo, because the stop was held to be constitutional, the statement (“I have a gun”) and the gun itself are not tainted and are admissible.

D. “High‑Crime Area” and Its Controversies

Courts routinely allow officers to consider whether an encounter takes place in a high‑crime area as a contextual factor in assessing reasonable suspicion. However:

• Presence in such an area alone cannot justify a stop.
• Civil rights and criminal justice advocates have criticized the “high‑crime area” concept as potentially being a stand‑in for race or socioeconomic status, particularly in heavily policed minority neighborhoods.

The Htoo opinion acknowledges these concerns explicitly but adheres to Supreme Court precedent (Wardlow) that this factor remains permissible, so long as it is only one component in a broader analysis.

E. “Printing” or Firearm Imprint

In firearm parlance, “printing” refers to the visible outline or bulge of a concealed weapon under clothing. Officers in Htoo testified that they saw:

• An imprint consistent with a gun under Htoo’s shirt.
• Htoo holding his waistband while running, a common behavior when a person is trying to keep a heavy object (like a gun) in place.

Alone, the mere presence of a firearm is not always suspicious—especially in jurisdictions where carrying is lawful. But under Tenth Circuit law (Young), the suspected possession of a firearm can be a significant factor in the reasonable‑suspicion analysis when combined with other indicators of illegality or danger.

F. Non‑Precedential “Order and Judgment”

The panel begins by clarifying that this decision is an “order and judgment”, which:

• Is not binding precedent in the Tenth Circuit, except under doctrines such as:
  • Law of the case (binding in the same litigation on remand or later appeal),
  • Res judicata (claim preclusion), and
  • Collateral estoppel (issue preclusion).
• May be cited for its persuasive value consistent with Fed. R. App. P. 32.1 and Tenth Circuit Rule 32.1.

Practitioners should therefore treat United States v. Htoo as persuasive authority, not binding, but still potentially influential in future reasonable‑suspicion litigation within (and sometimes beyond) the Tenth Circuit.

VI. Impact and Implications

A. Practical Impact on Gang‑Unit Policing

Htoo is fact‑specific, but it reinforces and illustrates several important points that are particularly salient in gang‑unit and urban policing cases:

• Association with known gang members matters. Officers may treat companionship with a known gang member who is a homicide person‑of‑interest and subject to warrants as probative in the reasonable‑suspicion calculus, especially when:
  • The encounter is in rival gang territory, and
  • Other suspicious signals (flight, hypervigilance, firearm cues) are present.
• Flight still carries significant weight. The decision underscores that running from police attention in a high‑crime area continues to be a powerful factor supporting reasonable suspicion under Wardlow.
• Firearm cues are important, even without certain knowledge of illegality. If officers reasonably believe a suspect is armed (based on visible imprint, mannerisms, waistband holding), that belief can substantially contribute to reasonable suspicion, particularly where the suspect is associated with known violent actors or active warrants are suspected.
• Officer credibility on “in‑the‑moment” observations is given deference. The Tenth Circuit’s reluctance to overturn the district court on credibility grounds—even when officers failed to document observations in reports—sends a signal that:
  • As long as body‑cam or other evidence does not directly contradict officers’ testimony, and
  • The testimony is plausible and partially corroborated,
  appellate courts are likely to uphold factual findings that support reasonable suspicion.

B. Legal Significance Within the Tenth Circuit

While not binding, the opinion will likely be cited in future cases for several propositions:

• Reaffirmation of totality analysis. The opinion is a crisp illustration of how the Tenth Circuit expects lower courts to apply the totality‑of‑the‑circumstances test and resist defense attempts to disaggregate and neutralize each factor.
• Use of “high‑crime area” evidence despite policy concerns. The panel acknowledges the potential for such labels to act as race proxies but nonetheless reaffirms they remain legitimate factors, consistent with Wardlow and Guardado, so long as they are not the only factor.
• Guidance on firearms as a reasonable‑suspicion factor. Building on Young, the decision confirms that officers may lawfully treat apparent firearm possession as part of the suspicion calculus, particularly when combined with other signs of criminality or danger.
• Open question on “common enterprise” beyond vehicles. By not resolving whether Dennison’s enterprise inference extends beyond vehicle occupants, the panel preserves flexibility for future panels or the en banc court to address this nuanced question when squarely presented.

C. Normative and Policy Implications

From a policy perspective, Htoo highlights ongoing tensions in Fourth Amendment law:

• Policing in high‑crime neighborhoods. The opinion underscores that residents of high‑crime or gang‑impacted areas remain subject to investigative stops triggered partly by their environment. The law still permits police to give context‑sensitive meaning to otherwise ambiguous behavior (such as running, or looking around nervously) in these neighborhoods.
• Racial and socioeconomic concerns. While the panel acknowledges that “high‑crime area” could function as a race or ethnicity proxy, it stops short of imposing any new constraints. Critics may argue that such decisions contribute to over‑policing of communities of color, while supporters may contend that they realistically address the risks officers face in gang‑related territories.
• Body‑cam evidence and officer reports. The fact that omissions in reports did not undermine officers’ credibility, given non‑contradictory body‑cam footage, suggests that:
  • Counsel challenging reasonable‑suspicion findings will need affirmative contradictions in video evidence, not just omissions, to prevail on credibility grounds.

VII. Conclusion

United States v. Htoo is a detailed, fact‑intensive application of the Fourth Amendment reasonable‑suspicion standard in a gang‑policing context. The Tenth Circuit affirms that:

• Officers had reasonable suspicion to detain Htoo even without proven knowledge of his warrants,
• Because the totality of circumstances—association with a known gang member and homicide subject, presence in high‑crime rival‑gang territory, hypervigilant behavior, flight upon police attention, and visible indications of a concealed firearm—collectively provided a particularized and objective basis to suspect criminal activity.

In doctrinal terms, the decision:

• Reaffirms the totality‑of‑the‑circumstances approach under Terry, Cortez, and Sokolow,
• Resists attempts to neutralize reasonable suspicion by dissecting each factor in isolation,
• Confirms that high‑crime area, flight, and apparent firearm possession remain potent contributors to reasonable suspicion, especially in gang contexts, and
• Leaves unresolved—but frames—the open question of extending the common enterprise inference outside the vehicle setting.

Although formally non‑precedential, Htoo will likely serve as a persuasive and practical guide in future suppression litigation involving:

• Gang‑related police activity,
• High‑crime urban areas,
• Suspect flight, and
• Field observations suggesting concealed firearms.

For practitioners, the case underscores the importance of:

• Developing or challenging a coherent narrative of the totality of the circumstances,
• Scrutinizing (or defending) officer credibility in light of body‑cam footage, and
• Recognizing that reasonable suspicion is a flexible, relatively low threshold, especially where multiple contextually suspicious factors converge.