Does a police officer have a reasonable suspicion of criminal activity based on the flight, confrontational behavior and lack of cooperation of an individual who fled the scene of the incident?

Illinois v. Wardlow (2000) 528 U.S. 119 [120 S.Ct. 673] (Wardlow) does not support the People's argument that appellant's flight, confrontational behavior, and lack of cooperation provided reasonable suspicion of criminal activity. In Wardlow, a four police car caravan converged in an area known for heavy narcotics trafficking. An officer in the fourth car observed the defendant standing next to a building holding an opaque bag. The defendant looked in the officer's direction, then ran through a gangway and alley. The officer, in his car, eventually cornered the defendant on the street, exited his car, detained the defendant, and found a handgun and ammunition during a patdown. (Id. at pp. 675-676.) Wardlow concluded that, although "flight is not necessarily indicative of ongoing criminal activity," the officer was justified in suspecting defendant's involvement in criminal activity based on the entire context of his "unprovoked" "headlong" flight. (Id. at pp. 676, 677.)