th amendment particularly that word was included for a reason and it's important the shot spotter does not give particular reasonable suspicion to stop anyone in a particular area in this case there was no description of a vehicle no make model color of the vehicle given no traffic violations or unusual behavior about this record or the vehicle which he was writing so can i so is it enough to stop a car when you know you have shots fired in a pretty particularized area i wouldn't nail it down to one house or the other but they know that this is this they're told this is the street shots fired and  not very many other people are on the road given the time of day so you see a car coming towards you is that enough when you as you just point out you don't know what kind of car you're looking for you don't know a lot of other details can you stop that car on the basis of reasonable suspicion that the people in that car might have been responsible for the shots but no your honor i think you need you need more than that simply blink and being in an area is is insufficient and that's the the difference that makes the guy should have added you know notoriously we hear this all the time high crime area high crime area and and just if we can dress to that point officer elephant said it's actually not unusual for a number of cars to be on the road a quarry and that's when the nightclubs close in peoria you're right though that was the only car on the on that particular block we would dispute that this is a high crime area officer elephants was was was big on that the city responded to the general area of north black male on foot cars leaving five minutes later we see mr it was car and the desk and video shows us very clearly so as it gets to the end of the block you can see the kind of the headlights of perpendicular as if they're turning on to the street opposite side by the way of where those shots occurred and immediately the lights go on and there's no way he had any particular facts about about about the vehicle its occupants or any sort of nexus if you need that need something reasonable suspicion is not a high stand we need something you need a color of a vehicle or  arguing on the fact that after the stop happens it turns out that rickman himself has a gunshot wound right that's not because he didn't know that when he stopped the car that's right and as well as the you know there's a lot made of this of this rolling back officer over said they were not trying to evade or complying with their with their or with it with his commands so it seems unusual for the discord then just to take that testimony that is not threatened report found it was justified for investigative reasons to ascertain whether contained the kims or witnesses that's clearly written in beaumont where the where the court ruled that stopping a car for identification purposes is deliber enough to justify suppression and of course you have to have reason your argument is you have to have reasonable suspicion about that car and if you're going to do witnesses you've got to comply with edmunds or you know it's something along those lines or so isolated but th requires very bothered though i mean here's here's ella for it's you know he hears about the shots here's this one car and he understood you to be saying that it was the officers judy just like the cargo well it's not it's not that i agree not following the carman you should what the cargo was and it's not seems like a radical notion at st blush but that's what exactly what they did officer didn't brewer doesn't mean you couldn't pursue them get the license plate number call in some backup and garner some of that reasonable suspicion some that's right your honor but again it was fifty five minutes twenty seconds later and it was closer in time and brewer matter seconds even in burgess i think it was two or three minutes and they were already a half mile away  stop the only car that they see leaving the scene of multiple gunshots by the only route of eat grass from that scene in a high crime neighborhood at four hundred and forty eight just a few minutes after the fire yeah i mean that that's it that's all they have they don't have any other information about who's in the car so you have to somehow say that's enough to create reasonable suspicion that one or more occupants of the car has committed a crime exactly your honor and and the government's brief dances around quite a few other things that i think are not helpful the only collective knowledge you have is that conveying of the nine hundred and eleven call through the he is that twenty to twenty seven ellis street that is actually halfway between the scene at the bottom of north ellis and archer which is that perpendicular street that crosses the credit is that information conveyed to ella fritz see here's here's here's the issue i am also happy with collective knowledge if you call judge flom and sat in tell him shots are at this it twenty two o three north alice or wherever and then judge foreman tells me the same things just relate among us but collective knowledge doesn't mean things that are only in your head that you do not convey to the intermediary person because i'm not relying on it if i never learned about it i mean you if it moves all the way through the system that you but i think i'm not sure that that information on the full transcript of the nine  eleven was what officer elephant scott i think he just got a summary from the dispatcher if you look i understand what you're saying your honor if you look at the government's exhibit five that's the transcript of the  exchanges between the dispatch and the officers here what dispatch did convey so again officer elephants on route that right he's on route because of spot shot or i get be because every ports have kind of gunfire leaving last seen going northbound and so forth and then a few minutes later there's also a black male on foot who ran northbound towards mclaren so who are there i can see no reason which this car is going to help much about  because the black male on foot running toward the clerk was long gone by the time the five minutes pass correct this is a teeny little street i think your honor though he appeared here's the core of our response to that i think officer trying to get more specificity out of this call i see it is corroborating to go to that area he's gets the spot shot a report and then he's told that the nine hundred and eleven calls are coming in so great you know keep anything we can you use i would i would i would disagree with one small aspect of the matter i don't think we can use the fact that the caller was calling from twenty's correct i think we can infer we can in er that that officer elephants would believe that caller that the dispatcher is as reporting on one call surely no one is going to call simply about cars on the street surely no one is going to call so you're conceding that the nine hundred and eleven i'm just replaying in my mind what you just read so i thought then when the dispatcher contacted officer ella fritz the dispatcher went so far as to say we're getting a nine  street there were no other cars on this particular street men could think it was a drug deal i mean honestly you guys have been here before us and all of the things i've just mentioned you know there are a bunch of people on the street in a elephants northville us because of shots fired the dispatcher knows he's heading to north of us because of shots fired the dispatcher is conveying additional information that the dispatcher has received r presumably because the on the dispatcher knew officer elephants and if i could just your honor go to a few other areas a few other issues that the defense has raised here if i could they argue about the nature of the area they argue that there's no evidence that it's a high crime but the only evidence that we have in the record about the nature of the area was officer l a for its testimony that he had worked the night time shift for the peoria police department for four and a half years and that he responded to reports of crime including gunfire and it was more than just that general area he actually said if i could be further court to page sixteen eleven area of north dallas to respond to reports of crime in this general area he says within a couple block radius i would say maybe once a night maybe a most couple of block radius of district eleven or a  couple block radius of dallas what it seems to indicate your honour's a couple of block radius of north fellas why does right you say that i mean because when you just now read it the st question that popped into my mind are what are the boundaries of district eleven because i mean i worry about this a lot because it's high crime area business seems to target low income minority neighborhoods in a very disturbing way maybe there's violence there you know but i think we need to be careful about i understand your say that i have less than a minute if i could just add one more point sure the defense says that we are improperly realize the fact that occurred after the start and we don't want to do that and we are not doing that i did want to point out though in relation to the passage of time the district court found it's a matter of leave that area because there's this big parking lot of that state facility right south of except that there is a strip of vegetation between the end of north ellis and god that is that is very much a dead end the only way to get out of that area a shooter on foot could easily read i'm also a strip of vegetation and be in the parking lot and out correct every minute correct but again we don't want to rely on facts that occurred afterwards but as it turned out the defendant had been involved in that shooting but that's not i mean we really honestly can't do it that way correct but it's our hindsight were the standard for the th man and i can guarantee you a great number of cases would come out differently and i understand that your honor but what we're saying is that three and a half minutes are our point is three and a half minutes is too thin is not too long to have to to find a car that was involved in those shots and the fact that if you know if there's a car involved in the mid all of course spot shattering the nine hundred and eleven person doesn't have any idea whether it's shots fired from the front porch where you're not in a car at all or whether it's shots fired from a vehicle or whether you actually fired shots on the ground then jumped into a vehicle the fact that mr rickman had been injured in that shooting again we're not relying on that for the stop really relying on that to say that three and a half minutes is not is the case is all about the stop it really i think it correct term but i think so but i think we need to consider the fact now saying that three and a half minutes is not too long mr rickman had been involved matter of fact well thank you very much  cassatt anything further we very very brief we see five minutes because officer elephants gets the alert in his vehicle four forty am he's already deciding to go to north ellis street and arrives there for forty five that's where we get the computer there so he doesn't need the intermediary of the dispatcher right for that and i'm collective knowledge no one in law enforcement had been a certain level of over reasonable suspicion and he didn't rely on anyone he said he was going to stop anyone in the general area so it's a little bit of book a red herring the collective the collective knowledge on the and just two final points just one you had mentioned before about they were the only car on the on the road when i could see it is a high crime area but even if it was according  that we know that in brewer they talk about you know there's a little bit of leeway for gunfire being different but that's a big difference we have lowered we did that in united states versus williams too right you know traffic stop of the implications of it or are serious for those living in actual high crime areas or near shot spotter let's think of the it's an astounding statement i'm sure officer over to the fine public servant it's an astounding statement i would stop anyone in the area parishioner a club patron anybody doesn't have that that unbridled discretion that that's disturbing under under his view all fifteen people at the end of the block could have been stopped could have been could have a question in that well the bar would put some real shade on that i think