Terry Stop

Brief detainment by police in the United States

Police investigative stops in the United States, often referred to as Terry stops , represent a critical intersection of law enforcement authority and individual liberties, specifically as they pertain to the Fourth Amendment of the U.S. Constitution, which safeguards against unreasonable searches and seizures . These stops allow law enforcement officers to briefly detain an individual if they possess reasonable suspicion that the person is involved in, or about to be involved in, criminal activity. This standard of reasonable suspicion is a lower threshold than the probable cause required for an arrest . When such a stop involves a pedestrian and includes a pat-down of their outer clothing for weapons, it is commonly known as a “stop and frisk.” When the subject of the stop is an automobile, it is typically referred to as a traffic stop . A particularly contentious variation is the pretextual stop , where law enforcement uses a minor traffic infraction as a justification to stop a vehicle for the purpose of investigating other, more serious suspected criminal activity.

While the Supreme Court of the United States has extensively shaped the legal landscape surrounding these encounters through its jurisprudence, Congress has notably refrained from establishing a comprehensive legislative baseline for police behavior in this regard. Consequently, much of the regulatory framework has emerged from state legislative actions, judicial decisions at both the state and federal levels, and, in some instances, local ordinances enacted by cities.

A significant area of concern among legal scholars and civil rights advocates revolves around the potential for implicit bias to influence an officer’s decision-making during an investigative stop. Critics argue that the existing legal framework, which permits Terry stops based on reasonable suspicion, may not adequately account for the possibility of officers acting on unconscious prejudices, potentially leading to racially skewed enforcement patterns. Furthermore, communities that experience disproportionately high rates of incarceration often find themselves subjected to more intense and punitive policing and surveillance practices, even when overall crime rates are in decline. This creates a cycle where heightened police presence can lead to more stops, reinforcing the perception of criminality in those areas.

Origins

The legal foundation for the Terry stop was firmly established in the landmark 1968 Supreme Court case of Terry v. Ohio . This pivotal decision centered on the actions of a police officer who, observing three men behaving in a manner he deemed suspicious—suggesting they might be casing a store for an armed robbery —detained them on the street. The subsequent pat-down of their outer clothing by the officer revealed a concealed firearm, leading to the arrest and conviction of two of the men for carrying a concealed weapon .

The men appealed their convictions, contending that the search, which uncovered the weapon, violated their rights under the Fourth Amendment . The Supreme Court, however, upheld the detention and the search, ruling that the officer possessed reasonable suspicion —a standard that could be articulated and was more than a mere hunch—that the individuals were potentially armed and dangerous. This “reasonable suspicion,” the Court determined, justified the brief investigative detention and the limited pat-down for weapons.

This ruling emerged during a period of significant social upheaval in the United States throughout the 1960s, marked by rising crime rates, widespread opposition to U.S. involvement in the Vietnam War , the burgeoning civil rights movement , and a series of race riots . Proponents of the Terry decision argued that it provided law enforcement with necessary tools to address the growing challenges of urban crime and social unrest. Conversely, critics voiced concerns that the ruling diluted the constitutional prohibition against unreasonable searches and seizures, while others praised it for striking a balance between public safety and individual liberties. The decision itself drew upon the “reasonableness clause” of the Fourth Amendment , which states: “The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated…” This clause is distinct from the “Warrant Clause,” which mandates that warrants shall only be issued upon probable cause and particularly describe the place to be searched and the persons or things to be seized.

Elements of a Terry Stop

The Supreme Court laid out specific criteria that, when met, permit a police officer to conduct a limited search for weapons during an investigative stop. These elements are:

• A police officer must observe conduct that is unusual and leads the officer to reasonably conclude that criminal activity may be occurring.
• This conduct must also lead the officer to reasonably believe that the subject of the stop may be armed and presently dangerous.
• The officer must identify themselves as a law enforcement officer.
• The officer must make reasonable inquiries related to the observed conduct.
• Crucially, nothing in the initial stages of the encounter should serve to dispel the officer’s reasonable fear for their own safety or the safety of others.

If these conditions are met, the officer is permitted to conduct a “carefully limited search of the outer clothing of the subject in an attempt to discover weapons.” Any weapons discovered during such a lawful search can then be used as evidence.

Expansion Through Case Law

The initial framework established in Terry v. Ohio has been significantly expanded and interpreted through subsequent Supreme Court decisions, broadening the scope of police authority in conducting investigative stops.

Reasonable Suspicion

Further information: Reasonable suspicion

For a police officer to possess reasonable suspicion sufficient to justify a stop, they must have “specific and articulable facts” that point towards an individual’s involvement, or impending involvement, in criminal activity. Because officers typically encounter civilians without direct supervisory oversight, they exercise considerable discretion in deciding whom to stop. The determination of reasonable suspicion is not based on a single factor but rather on the “totality of the circumstances,” meaning a constellation of facts, each of which might be insufficient on its own, can collectively form the basis for reasonable suspicion. The Supreme Court has acknowledged that “reasonable suspicion” is an inherently flexible and somewhat vague term, necessitating case-by-case adjudication.

The suspicion must be directed at an individual. While officers often rely on situational factors related to criminal behavior, subjective influences such as personal attitudes and departmental policies can also play a role, creating potential avenues for bias. Courts generally accept three primary sources of information to establish suspiciousness: information obtained from third parties (such as informants), observations of the suspect’s appearance and behavior, and the time and location of the suspected offense. Officers are permitted to define what they perceive as “normal” behavior and identify deviations from that norm. This subjective element has led to situations where actions that are typically innocuous, such as standing in a particular area, exhibiting nervousness, displaying unusual calmness, or walking away quickly, have been deemed sufficient for reasonable suspicion, especially when viewed through the lens of an experienced officer’s perspective. The danger here, as some critics point out, is that an officer’s experience might lead them to perceive innocent social interactions, like a hug or a handshake, as potential indicators of illicit drug deals.

It is important to note that merely identifying an individual as belonging to a broad category, such as a particular physical location, race, ethnicity, or fitting a general profile, is insufficient on its own to establish reasonable suspicion. However, stop-and-frisk practices have been validated in some instances based on factors like furtive movements, inappropriate attire for the location or time, carrying unusual objects (like a pillowcase, which in English law is associated with going equipped for burglary), providing vague or evasive answers to routine questions, refusing to identify oneself, or appearing to be out of place.

Prior to 1968, legal precedent generally required substantial evidence to justify any significant infringement on liberty or seizure of property. However, the Terry decision fundamentally altered this landscape by granting officers the authority to stop and search for weapons even in the absence of probable cause, based on the rationale that the potential danger posed by concealed weapons outweighed the intrusion of a limited pat-down.

Subsequent legal interpretations have indeed expanded police powers. While the original Terry case focused on armed violence and direct observation by officers, the case of Adams v. Williams (1972) broadened the doctrine to include situations where reasonable suspicion is based on secondhand information, such as the tip from an informant regarding drug possession . This precedent established that officers are not strictly required to witness suspicious behavior firsthand if their reasonable suspicion is derived from reliable information provided by an informant. Justice Marshall, in his dissent in Adams, expressed profound concern, foreseeing “a society in which innocent citizens may be stopped, searched, and arrested at the whim of police officers who have only the slightest suspicion of improper conduct.” Further expansion occurred with United States v. Hensley (1985), which permitted officers to stop and question individuals they recognized from “wanted” flyers issued by other law enforcement agencies. In Illinois v. Wardlow (2000), the Supreme Court ruled that an individual’s unprovoked flight from police officers in a high-crime area constituted reasonable suspicion justifying a stop.

During a Terry stop, officers commonly request detainees to identify themselves. Several states have enacted stop-and-identify statutes , which legally require individuals to provide their names to police upon request. The constitutionality of these statutes was affirmed in Hiibel v. Sixth Judicial District Court of Nevada (2004). While the specifics vary, a significant number of states and local jurisdictions have adopted such laws. In contrast, New York has, through its court system, placed limitations on the scope of Terry stops by establishing a four-tier continuum of police intrusion, each requiring a corresponding level of suspicion. This framework allows officers to detain individuals if they possess an “articulable and objectively credible reason.” For instance, in People v. DeBour, New York’s highest court permitted police to stop a person who simply crossed the street upon observing the police, suggesting that such behavior, in that context, could be interpreted as suspicious.

Lacking reasonable suspicion, police can still engage individuals in what is termed a consensual stop , which does not require probable cause or reasonable suspicion. The Supreme Court case of United States v. Mendenhall established that police officers are generally not obligated to inform individuals that a stop is consensual or that they are free to leave at any time. However, an individual can typically ascertain the nature of the encounter by asking, “Am I free to go?” If the officer indicates that the person is not free to leave, or fails to respond, the encounter has transitioned into a Terry stop. Conversely, if the officer confirms the person is free to go, they may leave. Mendenhall also clarified that a consensual encounter can morph into an unconstitutional Terry stop if circumstances suggest coercion, such as “the threatening presence of several officers, the display of a weapon by an officer, some physical touching of the person of the citizen, or the use of language or tone of voice indicating that compliance with the officer’s request might be compelled.” Officers who conduct unconstitutional Terry stops may face administrative disciplinary actions and civil lawsuits.

In Pennsylvania v. Mimms , officers stopped Mimms for a minor traffic violation (expired license plate) and, upon asking him to exit the vehicle, discovered a handgun. The court upheld the legality of the search, citing officer safety as the primary justification. However, dissenting justices expressed concern that this ruling further expanded the reach of Terry, potentially setting a precedent for officers to request actions from citizens through warrantless intrusions.

Search

During a Terry stop, a police officer is permitted to conduct a frisk , or pat-down, of a suspect’s outer clothing. This search must be strictly limited to actions necessary to discover weapons and must be predicated on reasonable suspicion that the individual is armed. However, under the “plain-feel doctrine,” which operates analogously to the plain-view doctrine , officers may seize contraband discovered during a lawful frisk, but only if the nature of the contraband is “immediately apparent.”

The Supreme Court has interpreted “immediately apparent” quite broadly. For instance, the Federal Law Enforcement Training Centers provides an example where an officer, during a frisk, feels a hard pack of cigarettes. If the officer, based on prior experience, knows that small switchblades or tiny guns could be concealed within such a pack, they are legally permitted to open it.

Subsequent case law has further liberalized the definitions of what constitutes a permissible frisk and what evidence is considered admissible evidence . In Michigan v. Long , the Supreme Court extended the scope of Terry stops to include searches of the passenger compartment of a vehicle if officers have reasonable suspicion that an occupant might access a weapon from that area. [Minnesota v. Dickerson] further clarified that contraband discovered during a Terry stop, if “immediately recognized” as such, is also subject to lawful seizure.

Consensual Search

The Supreme Court’s decision in Schneckloth v. Bustamonte (1972) established that individuals waive their Fourth Amendment protections against unreasonable searches when they voluntarily consent to a search . Crucially, police are not required to inform individuals of their right to refuse such a search. Justice Marshall, in his dissent, critiqued this as a “curious result that one can choose to relinquish a constitutional right—the right to be free from unreasonable searches—without knowing that he has the alternative of refusing to accede to a police request.” Despite this, several cities and states have enacted laws requiring police to inform citizens of their right to deny a search.

Traffic Stops

For all practical intents and purposes, a traffic stop is functionally equivalent to a Terry stop. During the duration of a traffic stop, both the driver and any passengers are considered “seized” within the meaning of the Fourth Amendment. The Supreme Court has ruled that drivers and passengers can be ordered to exit their vehicles without violating the Fourth Amendment’s prohibition against unreasonable searches and seizures. Furthermore, individuals can be frisked for weapons if officers have reasonable suspicion that they are armed and dangerous. If officers have reasonable suspicion that the driver or any occupants may be dangerous and that the vehicle might contain a weapon accessible to them, police may conduct a protective search of the passenger compartment. However, absent a search warrant or the driver’s consent, police generally cannot search the rest of the vehicle. Nevertheless, under the plain-view doctrine , they may seize and use as evidence any weapons or contraband that are visible from outside the vehicle.

In the case of Ohio v. Robinette (1996), the Supreme Court held that after an officer returns a driver’s identification documents, there is no requirement for the officer to inform the driver that they are free to leave. This means that even though the encounter has technically reverted to a consensual one, the officer can continue questioning, including requesting consent to search the vehicle.

Pretextual Stops

Pretextual stops represent a specific category of traffic stops that the Supreme Court deemed constitutional in Whren v. United States (1996). These occur when a police officer has underlying suspicions about a motorist, often related to drug possession, and uses a minor traffic violation—such as a broken taillight or a minor speeding infraction—as a pretext to initiate a stop. The defense in the Whren case argued for a “would-have” rule, suggesting that a stop should only be considered valid if a reasonable police officer would have made the stop solely based on the traffic infraction, irrespective of any other suspicions. Critics argue that pretextual stops can facilitate racial profiling , as officers can selectively choose from a multitude of minor traffic violations that most drivers commit, thereby targeting individuals based on discriminatory criteria rather than observed criminal behavior. In response to these concerns, sixteen states have enacted laws that prohibit pretextual stops when they are based solely on racial profiling or other immutable characteristics: Arizona, Arkansas, California, Colorado, Connecticut, Kansas, Maryland, Mississippi, Montana, Nebraska, New Jersey, New Mexico, Oklahoma, Rhode Island, Utah, and West Virginia.

Racial Disparities

The practice of Terry stops and subsequent searches has been a focal point for discussions regarding racial disparities in policing. It is theorized that police officers, through prolonged exposure to certain environments, particularly high-crime minority neighborhoods, may develop cognitive schemas that associate crime with race rather than focusing solely on specific suspicious behaviors. Studies suggest that officers with longer tenures on the force may be more prone to forming suspicions based on non-behavioral indicators. Furthermore, pervasive negative stereotypes within American culture—such as associating Black individuals with violence or white individuals with white-collar crimes—can inadvertently influence officers’ actions, even if they do not consciously hold these biases, making implicit bias a potential factor in arrest decisions.

A significant body of research suggests that Black and Hispanic individuals are disproportionately targeted for stops and searches compared to their representation in the general population and relative crime rates. The intensity and frequency of Terry stop regulations can also vary significantly by geographic area. For instance, areas perceived as having high crime rates, such as public housing developments, may require less evidence for an individual to be stopped. This practice places residents of these areas at a greater risk of detainment. The deployment of more police in areas deemed “high crime” can lead to higher arrest rates, which in turn are used to justify further increased policing, creating a self-perpetuating cycle.

While some studies have attempted to control for location-based stops, findings have been complex. One analysis indicated that, when controlling for location, white individuals were actually more likely to be found with a weapon than Black or Hispanic individuals. Another study suggested that the proportion of stops occurring during both day and night were similar across racial groups, leading some to interpret this as evidence that stop decisions were not based on the driver’s physical appearance. However, this same study was also interpreted to suggest that Black individuals were more likely to be detained for extended periods. The National Research Council has emphasized the need for more extensive research into the “complex interplay of race, ethnicity, and other social factors in police-citizen interactions.”

Further research has indicated that Black individuals are statistically more likely to experience the use of force during a stop compared to white individuals, with a 27% increase in the likelihood of force being used. This disparity extends to officers drawing their weapons, which occurred 28% more frequently when the individual stopped was Black. The study also found that even during consensual stops, Black individuals were 29% more likely to experience the use of force than other racial groups. Younger individuals were also found to be more susceptible to experiencing force compared to older individuals. In New York City, between 1996 and 2000, a disproportionately high number of complaints regarding officers’ use of force came from Black individuals. Investigations by both governmental and non-governmental organizations have corroborated instances of police-perpetrated abuse affecting individuals of all races. Some research has pointed to variations in nonverbal communication styles among different racial groups as a factor that may influence some officers’ suspicions.

One study from 2009 proposed that police officers might leverage their authority to enforce notions of masculinity. Given that the majority of police officers and individuals subjected to stops are men, officers may be susceptible to adopting a “culture of honor” stance and hypermasculinity , leading them to be more inclined towards physical aggression as a means of protecting their perceived social standing.

A 2015 study concluded that while immigration does not correlate positively with crime rates, immigrants are disproportionately stopped and arrested by police, fostering distrust in law enforcement. This study also argued that immigrants may possess less awareness of how to navigate police encounters, and repeated stops could further entrench their distrust of the police.

Effects

Usage of Force

The experience of minority citizens, who are not only more likely to be stopped by police but also more likely to experience the use of force following a stop, has been described as a form of racial or ethnic “double jeopardy.” Instances of police force can result in physical injury, death, costly civil litigation, public outcry, civil disorder, and a pervasive erosion of trust in law enforcement.

High-profile cases such as the killing of Eric Garner by the NYPD, the case of Freddie Gray and the Baltimore police, and the shooting of Michael Brown by Ferguson police are tragic examples where Terry stops escalated with fatal consequences. While racial disparities in the frequency of Terry stops are widely acknowledged, less is understood about the specific nature, prevalence, and contributing factors behind the use of force during these stops.

A study by Morrow et al. that analyzed NYPD’s stop, question, and frisk (SQF) records in 2010 aimed to quantify the frequency of force used during stops and to determine if the citizen’s race or ethnicity played a role in the decision to employ force. The study found that SQF tactics disproportionately targeted minority individuals, even after controlling for variables such as social and economic factors, precinct crime rates, and the racial or ethnic composition of neighborhoods. Furthermore, SQF tactics appeared to be ineffective in addressing crime, as only 6% of stops resulted in an arrest, and a mere 0.15% of stops led to the recovery of a gun. In 2013 alone, 44% of young minority New Yorkers reported being stopped by the NYPD nine or more times.

Utilizing data from the US Census Bureau for 2012, Morrow et al. conducted an analysis of racial and ethnic disparities in the use of force by the NYPD. Force was categorized into various types, including hands-on, suspect on ground, suspect against wall, weapon drawn, weapon pointed, baton, handcuffs, pepper spray, and other, which were further classified into “no force,” “physical/non-weapon force,” and “weapon force.” The study revealed that non-weapon force was employed in 14.1% of SQF incidents. However, when broken down by racial categories, the disparity became stark: while only 0.9% of stops involving white individuals resulted in non-weapon force, 7.6% of Black individuals and 5.0% of Hispanic individuals experienced non-weapon force—eight to nine times more frequently than whites. The researchers suggested that these disparities might be attributable to implicit biases held by police officers, potentially shaped by their cumulative experiences in the field.

Psychological and Emotional Harm

The impact of stop-and-frisk practices extends beyond immediate physical harm, inflicting significant psychological and emotional damage on individuals and communities. Scholars like Kwate and Threadcraft argue that stop and frisk constitutes a public health crisis, contributing to the “harassment, stress, and resource deprivation—if not outright death—of individuals.” These practices cultivate an atmosphere of pervasive fear, which can alter community members’ behaviors and restrict their freedom of action. The physical intrusion of pat-downs, coupled with the potential for escalation to physical or sexual violence, can be deeply traumatizing. Officers’ use of profanity and discriminatory slurs during these encounters further exacerbates negative feelings, leading residents to harbor anger, fear, and distrust towards the police.

For individuals with existing mental health conditions, particularly those with sensory disorders, pat-downs can be profoundly traumatic. Those who have experienced sexual trauma, which is regrettably prevalent among men with criminal justice histories and Black individuals in impoverished urban areas, may find the invasive nature of these searches to be a triggering event, leading to heightened stress, depression, and anxiety. The practice also increases the risk of sexual exploitation or assault, especially in vulnerable communities, including Black and impoverished sex workers and victims of sex trafficking. As methods for transporting drugs have evolved, some officers resort to more invasive searches, such as stripping individuals and conducting body searches, which can be deeply traumatizing for both drug users and non-users alike. Furthermore, civilians have reported instances where police officers delay transporting arrested individuals back to stations until their “quota” is met, forcing them to endure hours in the back of vans, often lacking seats, packed with numerous other individuals, and without access to basic necessities like a bathroom.

A study by Cooper et al. found that young men who do not use drugs reported feeling anxious during police stops, fearing that “unnecessary violence or life disruption was imminent during every police stop.” Individuals who have been subjected to frequent stops tend to develop higher levels of allostatic load , a measure of the cumulative wear and tear on the body from chronic stress, leading to diminished self-esteem and feelings of despair. When residents of a community perceive that they are being treated unfairly, particularly due to their social identity, they are more likely to anticipate stigma and rejection based on their race. Marginalized communities experiencing recurrent injustice at the hands of the police often develop deep-seated distrust and cynicism towards law enforcement and the legal system, a phenomenon known as legal cynicism . This cynicism can result in decreased cooperation with and respect for legal authorities. This erosion of faith in the system can lead to diminished civic and political engagement. Community members may become less inclined to seek police assistance when they believe law enforcement is not acting in their best interest, opting instead to rely on other members of the community. This distrust can be transmitted across generations, a process termed legal socialization , as a protective mechanism, perpetuating a cycle of fear within the community.

Moreover, the discovery of items during pat-downs that, while potentially incriminating, might also be related to harm reduction—such as clean needles or condoms—can inadvertently lead to arrests rather than public health interventions, posing a danger to public health.

Solutions

In response to widespread criticism regarding racial profiling and police violence, numerous police departments across the United States have begun implementing “courtesy policing” strategies. This approach emphasizes building rapport with the community through respectful and friendly interactions. Another related strategy is “legitimacy policing,” where officers aim to achieve desired outcomes by employing a blend of punitive and courteous tactics. While courtesy policing is intended to foster trust and facilitate information gathering, officers may shift to a more punitive and aggressive stance if they perceive non-compliance. However, communities of color often perceive these community policing efforts as degrading.

Cooper suggests that to address the issue of hypermasculinity contributing to aggression within the police force, officers should receive training that discourages the use of “command presence”—authoritative tones or physical intimidation—in situations where it is not warranted. Command presence should be reserved for genuinely dangerous situations, not for routine encounters. Instead of focusing solely on punishing perceived wrongdoers, officers should be encouraged to develop a comprehensive understanding of the circumstances. The emphasis in police training should shift from aggressive approaches to a more patient and de-escalatory methodology. Training should also include instruction on effective communication with civilians who may challenge authority and raise awareness of potential officer biases.

Terry stops were originally conceived to prevent imminent armed robberies. However, data from New York City indicates that approximately 90% of individuals subjected to stop-and-frisk were ultimately permitted to leave, suggesting they were not on the verge of committing serious criminal activity, which contradicts the original intent of Terry. Scholars like Hutchins advocate for narrowing the scope of Terry stops, proposing limitations to prevent certain police encounters from occurring altogether and restricting stops based on possessory offenses when supported only by reasonable suspicion. Goel calls for optimizing stops related to the criminal possession of a weapon (CPW), arguing that reducing the evidentiary threshold for such stops disproportionately impacts Black and Hispanic individuals and that optimization would lead to fewer racial disparities in Terry stops. Goel’s analysis of three million NYPD stops for CPW cases revealed that in approximately 43% of these stops, there was less than a 1% probability that the suspect actually possessed a weapon. Goel identified five specific circumstances during a stop that were more likely to result in the recovery of a weapon: a suspicious weapon being visible, sounds of criminal activity, a suspicious bulge on the person, a witness report, and an ongoing investigation.

Kwate and Threadcraft propose a three-pronged public health approach to address stop and frisk. First, they advocate for the inclusion of stop and frisk encounters in citywide health surveys to facilitate the investigation of associated health outcomes. Second, they suggest that cities should establish mechanisms for receiving reports of traumatic stops within 24 hours. Third, they propose the creation of a registry where communities can formally report police encounters. Torres emphasizes the need for more comprehensive data in stop-and-frisk reports, noting that current data collection can be inaccurate, particularly concerning Latinos who may identify as white or Black.

Data Collection

A growing number of states now mandate the collection of data related to stop-and-frisk practices. These states include Alabama, California, Connecticut, Florida, Illinois, Louisiana, Maryland, Massachusetts, Minnesota, Missouri, Montana, North Carolina, Nebraska, Nevada, Rhode Island, Texas, Washington, and West Virginia.

The Stanford Open Policing project, utilizing public record requests, has amassed data on approximately 60 million traffic stops conducted across 20 states between 2011 and 2015. North Carolina pioneered the statewide requirement for the release of all traffic stop data starting in 2000. Researchers analyzing 20 million traffic stops from this dataset found that African Americans, as a proportion of the population, were twice as likely to be pulled over compared to whites and four times as likely to be searched. Hispanic individuals were not found to be more likely to be pulled over, but they did exhibit a higher probability of being searched.

There is an ongoing movement to increase the public accessibility of police data nationwide. In 2015, the White House launched the Police Data Initiative, which, as of 2018, included 130 participating police departments, some of which provide datasets on stop-and-frisk incidents. These 130 departments collectively serve approximately 15% of the U.S. population.

See also

• Consent search case law
• Stop-and-frisk in New York City
• Sus law
• Powers of the police in England and Wales#Search without arrest

Notes

• ^ a b c d e f g h i j k l m n Several states require this data to be published, including Kansas. clarification needed