of ‘persons’ within the meaning of this provision.”). “This means, of course, that the stop must be supported by a reasonable and articulable suspicion of criminal activity, see Berkemer v. McCarty, 468 U.S. 420, 439, 104 S.Ct. 3138, 82 L.Ed.2d 317 (1984), and that the detention must be reasonable under the circumstances, Whren v. United States, 517 U.S. 806, 809-10, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996).” Chhien, 266 F.3d at 5-6. A reasonable, articulable suspicion is “more than a naked hunch,” but less than “either probable cause or evidence of a direct connection linking the suspect to the suspected crime.” Id. at 6. “In determining whether, in the absence of probable cause, an investigatory seizure and search violates the Fourth Amendment, [the First Circuit] 09 (8th Cir.2004) (<HOLDING>); United States v. Williams, 359 F.3d 1019 (8th
holding that the sugar tree ruse did not violate the fourth amendment when officers only stopped vehicles for minor traffic violations holding that police officers may stop vehicles when they observe minor traffic violations recognizing private damage action for fourth amendment violations by federal officers holding that the sugar tree checkpoint program violated the fourth amendment when officers operating the checkpoint were instructed to stop every vehicle that took the exit regardless of whether a traffic violation had occurred holding the purpose of a checkpoint was valid when officers stopped vehicles to look for any violations on the vehicles such as drivers license equipment or inspection