In State v. Williams the Washington Supreme Court attempted to set forth specific criteria for determining when a temporary detention exceeds the bounds of a Terry stop and becomes an arrest, with the concomitant probable cause requirement. The court relied on both the fourth amendment and article 1, section 7 of the state constitution as the bases for its standards. The holding, however, is fact-specific, and the court's discussion of the permissible scope and intensity of an investigatory stop does not adequately establish guidelines for the police to apply in a future situation. Further, because the court did not ground its decision firmly in state law, the limits of an investigatory stop in Washington may be modified by future federal rulings.
Beryl N. Simpson,
Terry Stop or Arrest? The Washington Court Attempts a Distinction—State v. Williams, 102 Wn. 2d 733, 689 P.2d 1065 (1984),
60 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol60/iss2/12