In re K.P.

Summary

The District of Columbia Court of Appeals held that police lacked reasonable, articulable suspicion under Terry v. Ohio to stop a group of juveniles based on an armed-threat report because the record did not establish a sufficiently particularized connection between the group stopped and the reported perpetrators. The court held that the resulting show-up identification should have been suppressed and reversed the adjudication of delinquency, remanding for further proceedings.

Holdings

1. The police lacked reasonable, articulable suspicion to stop the group because the record contained no sufficiently particularized identifying information connecting that group, much less K.P. individually, to the reported threats.
2. The show-up identification should have been suppressed because it was the product of the unlawful seizure.
3. The admission of the show-up identification was not harmless beyond a reasonable doubt, so the adjudication of delinquency had to be reversed.

Questions Presented

1. Whether police had reasonable, articulable suspicion under Terry v. Ohio to stop and frisk the group of juveniles, including K.P., based on the information conveyed by the complainant and the officer's conclusory assertion that the group matched an unknown description.
2. Whether the complainant's show-up identification was the product of the unlawful seizure and therefore should have been suppressed.
3. Whether admission of the show-up identification was harmless beyond a reasonable doubt in light of the complainant's purported in-court identification.

Disposition

reversed_and_remanded