Motion to Suppress Arguing that the Court should Discount Police Observations of “Blading” in Reasonable Suspicion Analyses

This draft motion argues that courts should discount officer observations of “blading” when conducting reasonable suspicion analyses, because research shows that blading is a conclusory term that describes amorphous, innocuous, and contradictory behavior. This is particularly true when the term is applied to Black and brown community members who are trained to fear and avoid police. The motion asks the court to join others across the county in holding that “blading” is a generic label based on police hunches and is insufficient to establish reasonable suspicion of criminal activity.  These same arguments could be applied to reliance on “blading” as indicative of criminal activity for probable cause analyses.