## Facts

- Two men robbed a tavern in St. Bernard, Ohio; police later received an informant tip that Thomas Hensley drove the getaway car.
- A St. Bernard officer issued a “wanted flyer” to nearby departments stating Hensley was “wanted for investigation,” describing him, identifying the robbery’s date and location, and requesting that he be “pick[ed] up and h[eld].”
- Covington, Kentucky officers located Hensley driving a white Cadillac and stopped him based solely on the flyer after unsuccessfully trying to confirm whether a warrant existed.
- During the stop, an officer recognized a passenger as a convicted felon and saw a revolver butt protruding from beneath the passenger seat.
- Police arrested the passenger and searched the vehicle, discovering additional handguns; Hensley was arrested.
- Hensley was federally indicted for being a convicted felon in possession of firearms under 18 U.S.C. § 922.
- The district court denied Hensley’s suppression motion and he was convicted; the Sixth Circuit reversed, treating the stop as unlawful because the suspected crime was completed and the flyer was insufficient.

## Issues

1. Whether police may conduct a *Terry*-type investigative stop based on reasonable suspicion that a person was involved in a completed felony.
2. Whether officers may lawfully stop a suspect in objective reliance on a flyer issued by another department, and what Fourth Amendment showing must support the flyer.

## Decision

- The Supreme Court reversed the Sixth Circuit and reinstated the judgment based on the admissibility of the seized firearms.
- A *Terry* stop is permitted when police have reasonable suspicion, supported by specific and articulable facts, that a person was involved in or is wanted in connection with a completed felony.
- Officers may rely on a wanted flyer or bulletin from another department to justify a *Terry* stop, so long as the issuing department itself possessed reasonable suspicion.
- The stop and ensuing seizures did not violate the Fourth Amendment under these standards, given the suspected armed robbery and the observation of a firearm in plain view leading to probable cause for arrests and seizure.

## Legal Principles

- Reasonable suspicion can justify a brief investigative stop to investigate involvement in a completed felony, not only imminent or ongoing crimes.
- Inter-agency communications (flyers/bulletins) may supply the reasonable suspicion for a stop under a “fellow officer/collective knowledge” approach: the stopping officer may act on the bulletin if the issuing agency had the required factual basis.
- The permissibility of the stop depends on the scope and duration remaining consistent with *Terry* limits and on whether subsequent actions (arrests/searches/seizures) are supported by independent grounds such as plain-view observations and probable cause.

## Conclusion

The Court held that the Fourth Amendment permits *Terry* stops to investigate reasonable suspicion of a completed felony and permits officers to act on another department’s flyer when the issuing agency had reasonable suspicion, validating the stop that led to discovery of the firearms.


United States v. Hensley, 469 U.S. 221 (1985)