In a Brooklyn Law Review article entitled Stop and Frisk City, Fallon (2013) writes, “...as a result [of the ambiguity of lower courts’ decisions on stop and frisk], there are few checks on the tremendous discretion given to the NYPD in the stop and frisk context. In 2012 alone, ‘New Yorkers were stopped by the police 532,911 times. 473,644 were totally innocent (89%), 284,229 were Black (55%), 165,140 were Latino (32%), [and] 50,366 were White (10%)’" (p. 321). This quote contains two of the common arguments against stop and frisk. First, 89% of those stopped were totally innocent. This is one of the most commonly cited statistics by critics of the policy, and with good reason. Terry narrowly outlined why an officer may stop and frisk a person, yet the New York City numbers suggest that officers are making stops and frisking beyond when they have reasonable suspicion and may be motivated by other