By Esteban Cardona
It was a normal Sunday for Tyreek Hill, until it was not. Tyreek Hill—also known as “cheetah”—a high-profile wide receiver for the Miami Dolphins.[1] He is the founder of the Tyreek Hill Family Foundation whose founding vision is to “empower kids to be the best they can be.”[2] The foundation helps funds scholarships, free football camps, and more.[3] He is also known for his partnership with the Boys & Girls Club in Miami locally. [4]
However, even the most well-respected athletes in the community are not immune from Police overreach. Hill was on his way to work for the first game of the Dolphin’s 2024-25 season.[5] Body cam footage released by the Miami-Dade Police Department show officers pull over Hill for suspected speeding at 10:17 AM on September 8, 2024. The not uncommon police stop occurred on the outskirts of the Hard Rock Stadium in Miami Gardens, where the Dolphins were slated to play their home opening game of the season.
Before Officers approach pull Hill over, they inform him that he was speeding. Hill responds, “How fast was I going?” Two police officers surround either side of the vehicle, at which point the officer on the driver sides knocks on the glass. Hill lowers his window and hands the police officer his driver’s license. The police officer ignores the request and asks why Hill did not have a seatbelt on.
Hill requests that the police officer give him his speeding citation so that he can arrive to the game in a timely manner. Hill then proceeds to close his window as he awaits for his driving citation. The police officer knocks on the window as Hill can be seen putting on his seatbelt.
Hill lowers the window a fraction, after the police officer can be heard threatening Hill to comply or else the officer will “get you out of the car.” When the window is not lowered to the officer’s satisfaction, several police officers start yelling expletives at Hill in attempt to corral him out of his car. Hill complies with the officer’s request by opening the door, at which point two officers forcibly grab Hill by the arms and wrestle Hill to the floor. Hill can be heard yelling into his phone telling his agent “I’m getting arrested.”
One officer can be seen kneeling on Hill’s back and pressing Hill down by the back of the neck while another officer grabs Hill’s arms and several other officers stand by. The officers begin to berate Hill by yelling at him “when we tell you to do something, you do it . . . not what you want, you are a little f******* confused.” Hill is quickly placed in hand cuffs.
At this point Hill begins to try to deescalate the situation by telling officers to take him to jail if they need to, but to relax. The main officer responds by saying “we will.” Hill continues to comply as he is lifted off his stomach and escorted to the sidewalk by police. The police then request Hill to sit down, at which point Hill responds by telling Police that he will. But not fast enough for the police’s satisfaction. At this point one officer pushes down on Hill’s shoulder while another runs up behind him and in a chokehold force him to sit. Hill can be heard screaming “I just had surgery on my knee.”
Several people can be seen approaching, curious as to the events unfolding as the police yell at everyone to back off. At this point Hill begins to request the presence of his attorney and agent Jordan Rosenhaus, as he yells to anyone who will listen “call Drew, call Drew, call Drew.” Hill then questions police as to why they were “beating and choking” him and continually repeats to officers “I am not going anywhere, I am chill.” He reassures police officers that “I am not going to run.”
Hill is then detained but not arrested for twenty tense minutes. Once Hill’s attorney arrives and talks to police officers the handcuffs are removed. Hill was ultimately cited for careless driving and driving without a seatbelt.
Director of Miami-Dade Police, Stephanie V. Daniels, released a statement after the incident “I have initiated an Internal Affairs Investigation to ensure a thorough review of the matter. One of the officers involved in the incident has been placed on administrative duties while the investigation is conducted.”[6]
Local Police union president Steadman Stahl released a statement claiming Hill was “briefly detained for officer safety . . . and for their immediate safety, placed Mr. Hill in handcuffs.”[7] While deeply unsettling, the right for police to detain individuals was enshrined by the Supreme Court of the United States in 1968. In Terry v. Ohio, the Court was faced with the question of when a police encounter implicates a seizure under the Fourth Amendment of the United States Constitution.[8] Under the definition and test laid out by the Court, Hill was seized by police officers.[9]
Even so, the Court makes clear that the inquiry does not stop there but must be deemed unreasonable before it becomes a constitutional violation.[10] It comes as no surprise that to justify the behavior of police officers on September 8th, 2024, the Police Union declared that the actions of the police are shielded under the banner of police safety.[11] Yet notably, Hill was never asked about any weapons upon being detained.[12] Hill was never searched for a weapon.[13] These actions call into question the veracity of claims that the detainment was necessary for safety reasons. Furthermore, at the end of the encounter Hill can be seen as shaking hands with all the police officers involved.[14] It is unclear whether Hill will challenge in court whether the police officer can “point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.”[15]
Police officers are often given a great latitude of deference in justifying Terry stops because the standard for a temporary detainment is “articulable reasons” or “founded suspicions”, a bar much lower than probable cause.[16] This low standard disproportionately affects African Americans and Hispanic Americans.[17] These normative results have drawn great criticism in both legal circles and across communities at large.[18]
At the end of the day Hill was released and went on to notch a 130-yard (with a touchdown to boot) game.[19] No harm, no foul, right? Not so. No public information is published on the number of Terry stops Florida police departments carry out in a year. However, not all Terry stops end with a one-hundred-plus-yard game in the National Football League. Some end in death.[20] As a trial court in New York found, “Eric Garner died on July 17, 2014, while being arrested by New York City Police Officers in Staten Island.”[21]
The history of Terry stops, plagued with improper targeting, and inarticulate rules which grant police officers great legal immunity begs the question: should police reform their Terry stop practices? Should the Court create greater scrutiny by revising the currently low “reasonable suspicion” standard?
[1] Miami Dolphins Roster, https://www.miamidolphins.com/team/players-roster/ (last visited Sep. 20, 2024).
[2] Tyreek Hill Family Foundation, https://www.tyreekhillfamilyfoundation.org/about (last visited Sep. 20, 2024).
[3] Id.
[4] Id.
[5] David Goodhue and Douglas Hank, “Miami-Dade cops release body-cam footage after Tyreek Hill cuffed before game.” Miami Herald (Sep. 20, 2024), https://www.miamiherald.com/news/local/community/miami-dade/article292207400.html.
[6] Miami-Dade Police (@MiamiDadePD), X (Sep. 8, 2024, 4:14 PM), https://x.com/MiamiDadePD/status/1832875203816284510.
[7] Andy Slater (@AndySlater), X (Sep. 9, 2024, 11:55 AM), https://x.com/AndySlater/status/1833172383202414742 .
[8] Terry v. Ohio, 392 US 1, 16 (1968).
[9] See Id. (“It must be recognized that whenever a police officer accosts an individual and restrains his freedom to walk away, he has ‘seized’ that person.”)
[10] Id. at 20.
[11] Slater, Supra note 8.
[12] Goodhue and Hank, Supra note 5.
[13] Goodhue and Hank, Supra note 5.
[14] Goodhue and Hank, Supra note 5.
[15] Terry, 392 US at 21.
[16] See State v. Cortez, 449 U.S. 41, 417 (1981).
[17] David A. Harris, Frisking Every Suspect: The Withering of Terry, 28 U.C. Davis L. Rev. 1, 43-44 (1994).
[18] Id.
[19] ESPN Player Statistics, https://www.espn.com/nfl/player/_/id/3116406/tyreek-hill (last visited Sep. 20, 2024).
[20] Staten Island Branch of NAACP v. State of New York Grievance Comm. for Second, Eleventh & Thirteenth Judicial Districts, 31 N.Y.S. 3d 782, 784 (N.Y. Sup. Ct. 2016).
[21] Id.
