A Cuyahoga County Court of Appeals has recently ruled that just because a suspect is leaning into a car and talking to someone late at night in a known high drug activity area, does not mean that the police officer has enough "reasonable suspicion" to believe that there might be criminal activity involved. In State v. Lynch, the Court ruled that just because Lynch was leaning into a car late at night in a high crime area of Cleveland did not mean, without more, that the officers had "reasonable suspicion" to believe that a crime might be in progress. This "reasonable suspicion" holding is important because police officers may only pull a person over or detain that person if the officer involved has "reasonable suspicion" that the person is possibly involved in criminal activity. "Reasonable suspicion" is standard somewhat below the "probable cause" standard necessary for an actual arrest.
This particular ruling may have way more to do with a prosecutor's failure to get more incriminating facts into the record (there were probably more out there that were just not introduced by the prosecutor) than it does with any bright line rule of law. "Reasonable suspicion" court rulings are always very fact specific - and each case facts can be somewhat different from a previous case facts. Motion to suppress on these types of cases are often more art than law.