In this context, “surroundings” means the area immediately around the arrestee—the space within the arrestee’s reach that could be searched to protect officer safety and to preserve evidence. That broad surrounding space is what police can squarely rummage through during a search incident to arrest, not just items the arrestee happens to carry or store elsewhere. So it’s not the arrestee’s personal effects, bank records, or fingerprints, but the area around them.

For an act to qualify as an attempt, two things must be present: a clear intent to commit the offense and an action that moves beyond mere preparation into a substantial step toward completing the crime. The substantial-step requirement means the defendant has taken concrete, purposeful steps that strongly indicate imminent success, not just thoughts, plans, or dreams. Examples would be actions like entering a building with the intent to steal or loading tools and approaching a bank with the plan to rob it. Merely thinking about the crime without taking action isn’t enough, because there’s no act moving toward completion. A completed crime isn’t an attempt at all—it's the actual offense. A confession after the fact doesn’t show an attempt, since it occurs after the crime is already done (or claimed), and it doesn’t establish the required substantial, purposeful step.

In evaluating police use of force, the key idea is that what matters is how a reasonable officer would view the situation based on the information available at the moment the force was used. This means the specific facts known to the officer at the time drive whether the force was reasonable. That real-time awareness is essential because it guards against judging actions with the benefit of hindsight and different circumstances. So, the factor that matters is the facts known to the officer at the time. This includes what the officer believed about threats, the suspect’s actions, the severity of the situation, and any imminent danger to the officer or others. The other options don’t fit because the officer’s personal feelings, or the department’s post-incident policy, don’t determine the reasonableness of a split-second decision on the scene. The suspect’s race is not a valid factor in assessing objective reasonableness and would be inappropriate to consider in judging the actions taken.

The Litchfield test uses a balancing approach to determine whether a police action is reasonable by looking at three elements together: how invasive the intrusion is (extent of intrusion), how much suspicion justifies the action (degree of suspicion), and how necessary the action is to achieve a legitimate law enforcement objective (extent of law enforcement needs). This means no single factor alone decides reasonableness; the combination of how invasive the action is, how strongly it is supported by suspicion, and how essential the objective is all have to be weighed. When intrusion is highly invasive, there must be strong suspicion and a clear need for the action; when intrusion is less invasive, the bar for suspicion and necessity can be lower. Because all three factors are considered in tandem, the test encompasses all of them.