Graham, 490 U.S. at 396 (emphasis supplied). Officers conducting Terry stops may, therefore, "use such reasonable force as may be necessary to" effectuate the stop, United States v. Haye, 825 F.2d 32, 35 (4th Cir. 1987), "to maintain the status quo[,] and to protect their safety," United States v. Sinclair, 983 F.2d 598, 602 (4th Cir. 1993) (holding that officer's decision to draw his weapon during a Terry stop was not improper even though the officer "had no reason to believe [the suspects] were armed and dangerous"); see also, e.g., Young v. Prince George's Cty., 355 F.3d 751, 755 (4th Cir. 2004) (citing prior cases upholding the use of handcuffs and drawing of weapons during Terry stops). To be sure, a bite from a police canine is a significant use of force.

Because the search of Salas' bag was consensual, see Schneckloth v. Bustamonte, 412 U.S. 218, 227, 93 S.Ct. 2041, 2047-48, 36 L.Ed.2d 854 (1973) (defendant need not have known of his right to refuse search for consent to be valid), the issue in this case involves whether at the time the officers discovered the cocaine in Salas' bag, they had probable cause to arrest defendant. Defendant's reliance upon United States v. Haye, 825 F.2d 32, 34 (4 Cir. 1987) is misplaced. In Haye, we explained that under Reid v. Georgia, 448 U.S. 438, 100 S.Ct. 2752, 65 L.Ed.2d 890 (1980), the presence of characteristics fitting a drug courier profile without more does not provide DEA agents with a reasonable suspicion, sufficient to justify an involuntary investigative detention.

Thus, the Court held that as a matter of law the law enforcement agent could not have reasonably suspected Reid of criminal activity on the basis of the observations made. The Fourth Circuit has recently held that travel to and from a source city and nervousness do not constitute reasonable suspicion. United States v. Haye, 825 F.2d 32 (4th Cir. 1987). In Haye, the officers stopped the suspects, who had just arrived on a plane from Miami, based on their observations which were consistent with the drug courier profile.

In United States v. Haye, officers sought to question several men carrying bags through an airport who "exhibited some of the characteristics of [a] drug courier profile." 825 F.2d 32, 33 (4th Cir. 1987). Once approached, we noted, the subjects "could have declined to answer questions and walked away."

" 825 F.2d at 41. In U.S. v. Haye, 825 F.2d 32 (4th Cir. 1987) DEA agents at Washington National Airport attempted to question two individuals, Haye and Reid, who met the drug courier profile. When the plain clothesmen identified themselves as law enforcement officials, Haye and Reid immediately fled, each going in a different direction.

The Fourth Circuit has acknowledged that although Terry stops should be minimally intrusive, officers may use “such reasonable force as may be necessary” to seize a suspect. Maney v. Garrison, 681 Fed.Appx. 210, 220 (4th Cir. 2017) (quoting United States v. Haye, 825 F.2d 32, 35 (4th Cir. 1987)).

While the parties do not raise the point, it is well settled that objectively reasonable physical force, as employed here, may be used to accomplish a Terry stop. See, e.g., United States v. Haye, 825 F.2d 32, 35 (4th Cir.1987) (“By its very nature ... a Terry stop is involuntary, and the suspect is not free to avoid it by flight. To that extent, his freedom is limited, and the policeman is authorized to use such reasonable force as may be necessary to accomplish the purpose of the limited stop.”).

Although the instant case was not decided on the basis of the drug courier profile, Reid is instructive in its teaching that "more [is] required than the presence of drug courier profile characteristics." United States v. Haye, 825 F.2d 32, 34 (4th Cir. 1987). Other factors also must be present sufficient to arouse a "particularized suspicion" that the defendant is engaging in criminal activity.

We have reviewed the record and the parties' briefs and conclude that officers had reasonable and articulable suspicion that Wallace was engaged in criminal activity when they stopped him. See Illinois v. Wardlow, 528 U.S. 119, 124 (2000); United States v. Haye, 825 F.2d 32, 34 (4th Cir. 1987). Accordingly, we affirm the district court's judgment.

Wardlow, 528 U.S. at 125, 120 S.Ct. 673 (internal quotation marks and citations omitted). See also United States v. Haye, 825 F.2d 32, 34 (4th Cir. 1987) (Defendants, instead of declining to answer questions and walking away, panicked and fled, giving officers "reasonable suspicion for a brief, involuntary, investigative stop.") Smith contends that the elements considered by the district court to support reasonable suspicion are insufficient.