An anonymous tip alleging a person is carrying a weapon without additional corroboration or indicia of reliability does not establish reasonable suspicion for a stop and frisk.
After receiving an anonymous tip that a young male at a bus stop was carrying a gun, police officers arrived at the location and frisked the individual. The respondent moved to suppress the firearm found during the search. The Court considers whether an anonymous tip alleging the possession of a weapon is sufficient, without additional corroboration, to justify a stop and frisk. The Court holds that an anonymous tip must be reliable in its assertion of illegality, not merely in its ability to identify a specific person. Because the tip provided no predictive information or other indicia of reliability, it did not establish the reasonable suspicion necessary for the search.
At page 271 Measuring suspicion based on informant reliability and predictive information269 citing cases“all the police had to go on in this case was the bare report of an unknown, unaccountable informant who neither explained how he knew about the gun nor supplied any basis for believing he had inside information about j.l.”
- Martinez v. State, 348 S.W.3d 919 (Tex. Crim. App. 2011).published But see Florida v. J.L., 529 U.S. 266, 275 , 120 S.Ct. 1375 , 146 L.Ed.2d 254 (2000) (Kennedy, J., concurring) (faulting the police officer for acting on an anonymous tip and pointing out that "[t]he record does not show whether some notat…
- United States v. Harrington, 56 F.4th 195 (1st Cir. 2022).published([R]easonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- Lewaco Leyultee Clay v. Commonwealth of Kentucky, No. 2020 CA 001525 (Ky. Ct. App. Dec. 1, 2022).unpublished See J.L., 529 U.S. at 271, 120 S. Ct. at 1379 (“The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.”).
- Mcintyre v. Liciardello, No. 2:13-cv-02773, 2020 WL 605717 (E.D. Pa. Feb. 7, 2020).(This post-hoc justification for stops and searches has been repeatedly rejected.)
- Michael Frank Lapace v. State of Florida, 257 So. 3d 588 (Fla. 2d DCA 2018).published (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- Commonwealth of Virginia v. Jermaine Durell Spence, No. 1515141 (Va. Ct. App. Jan. 9, 2015).unpublished ([R]easonable suspicion . . . requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.)
- People v. Smulik, 964 N.E.2d 183 (Ill. App. Ct. 2d Dist. 2012).published(The anonymous call concerning [the defendant] provided no predictive information and therefore left the police without means to test the informant’s knowledge or credibility.)
- Martinez, John David, No. PD-1238-10 (Tex. Crim. App. June 29, 2011).published See J.L ., 529 U.S. at 272 ("reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality . . .."); U.S. v. Benavides , 291 Fed.
- People v. Allen, 950 N.E.2d 1164 (Ill. App. Ct. 4th Dist. 2011).published (The anonymous call *** provided no predictive information and therefore left the police without means to test the informant’s knowledge or credibility.)
- United States v. Kent, 531 F.3d 642 (8th Cir. 2008).published(All the police had to go on in this case was the bare report of an unknown, unaccountable informant who neither explained how he knew about the gun nor supplied any basis for believing he had inside information about J…)
Show 196 more citing cases
- People v. Mario T., 875 N.E.2d 1241 (Ill. App. Ct. 1st Dist. 2007).published See Florida v. J.L., 529 U.S. at 271, 120 S.Ct. at 1379, 146 L.Ed.2d at 260 ("reasonableness of official suspicion must be measured by what the officers knew before they conducted their search").
- United States v. Jervis Lavern Goodrich, 450 F.3d 552 (3d Cir. 2006).published “The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.”
- State v. Williams, 887 A.2d 190 (N.J. Super. Ct. App. Div. 2005).published See, e.g., Florida v. J.L., supra, 529 U.S. at 271, 120 S.Ct. at 1379 , 146 L.Ed. 2d at 260-61 ("The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search."); United States v. Sh…
- State v. Hopkins, 117 P.3d 377 (Wash. Ct. App. 2005).published (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search. All the police had to go on in this case was the bare report of an unknown, unaccountable informan…)
- United States v. Brown, No. 04-4353 (4th Cir. Mar. 25, 2005).published (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- United States v. Quarles, No. 02-4209 (4th Cir. May 27, 2003).published (The reason- ableness of official suspicion must be measured by what the officers knew before they conducted their search)
- United States v. Robinson, No. 00-1328 (3d Cir. Sept. 13, 2002).published (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- Commonwealth v. Barros, 755 N.E.2d 740 (Mass. 2001).published (reasonableness of official suspicion must be measured by what the officers knew before they conducted their search)
- United States v. Kenneth King, 227 F.3d 732 (6th Cir. 2000).published “The reasonableness of official suspicion must be measured by what the officers knew before they conducted then-search.”
- People of Michigan v. Delon Martease Bouler, No. 379121 (Mich. Ct. App. Sept. 22, 2026).unpublished “the reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.”
- Commonwealth v. Smith, 172 A.3d 26 (Pa. Super. Ct. 2017).published “the reasonableness of official suspicion must be measured by what the officers lmewrefore they conducted their search.”
- Sanchez, Reinaldo, 538 S.W.3d 545 (Tex. Crim. App. 2017).published“the reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.”
- United States v. Mitchell, 388 F. App'x 328 (4th Cir. 2010).unpublished
- Commonwealth v. Brown, 250 S.W.3d 631 (Ky. 2008).published
- Carl Richard Cook v. Rankin Cnty., No. 2012-CT-01553-SCT (Miss. Oct. 16, 2014).published
- Carl Richard Cook v. State of Mississippi, 159 So. 3d 534 (Miss. 2015).published
- United States v. Hauk, 412 F.3d 1179 (10th Cir. 2005).published
- United States v. Brown, 496 F.3d 1070 (10th Cir. 2007).published
- United States v. Copening, 506 F.3d 1241 (10th Cir. 2007).published
- United States v. Monteiro, 447 F.3d 39 (1st Cir. 2006).published
- United States v. Kareem Brown, 448 F.3d 239 (3d Cir. 2006).published
- United States v. Abdul R. Muhammad, 463 F.3d 115 (2d Cir. 2006).published
- People v. Turner, 219 Cal. App. 4th 151 (Cal. Ct. App. 2013).published
- State v. Herrington, 961 So. 2d 1271 (La. Ct. App. 2007).published
- State v. Taylor, 694 S.E.2d 60 (S.C. Ct. App. 2010).published
- United States v. Crandell, 509 F. Supp. 2d 435 (D.N.J. 2007).published
- Baptiste v. State, 995 So. 2d 285 (Fla. 2008).published
- People v. Horton, 767 N.W.2d 672 (Mich. Ct. App. 2009).published
- State v. Torelli, 931 A.2d 337 (Conn. App. Ct. 2007).published
- Kellems v. State, 816 N.E.2d 421 (Ind. Ct. App. 2004).published
- State v. Crawley, 901 A.2d 924 (N.J. 2006).published
- People v. Long, 861 N.E.2d 335 (Ill. App. Ct. 2d Dist. 2007).published
- People v. Rollins, 892 N.E.2d 21 (Ill. App. Ct. 4th Dist. 2008).published
- People v. Miller, 824 N.E.2d 1080 (Ill. App. Ct. 1st Dist. 2005).published
- People v. Lindsey, 148 Cal. App. 4th 1390 (Cal. Ct. App. 2007).published
- Garcia v. Commonwealth, 335 S.W.3d 444 (Ky. Ct. App. 2010).published
- Commonwealth v. Marr, 250 S.W.3d 624 (Ky. 2008).published
- United States v. Forte, 412 F. Supp. 2d 258 (W.D.N.Y. 2006).published
- People v. Dolly, 150 P.3d 693 (Cal. 2007).published
- United States v. Freeman, 735 F.3d 92 (2d Cir. 2013).published
- State v. Kevin Gamble (071234), 95 A.3d 188 (N.J. 2014).published
- State v. Rodriguez, No. S-13-062 (Neb. Aug. 29, 2014).published
- Srisavath v. City of Brentwood, 243 F. App'x 909 (6th Cir. 2007).unpublished
- State v. Ebert, 2015-Ohio-5012.published
- Brymon Hamp, Jr. v. State of Mississippi, 207 So. 3d 684 (Miss. Ct. App. 2016).published
- Ames v. State, 153 A.3d 899 (Md. Ct. Spec. App. 2017).published
- State of Iowa v. Leon Kooima, 833 N.W.2d 202 (Iowa 2013).published
- Ernest Foster, Sr. v. Jeremy Hellawell, 908 F.3d 1204 (9th Cir. 2018).published
- Birdie Jean Jackson v. State, No. 02-19-00370-CR (Tex. App.—Fort Worth Apr. 22, 2021).unpublished
- United States v. Gaines, No. 19-3177 (10th Cir. May 25, 2021).unpublished
- State v. Tidwell (Slip Opinion), 2021-Ohio-2072, 175 N.E.3d 527.published
- State v. King, 184 So. 3d 215 (La. Ct. App. 2015).published
- Berry v. State, 86 So. 3d 595 (Fla. 1st DCA 2012).published
- State of Iowa v. Theodore W. Buselmeier, 974 N.W.2d 183 (Iowa Ct. App. 2021).published
- Furr v. State, 499 S.W.3d 872 (Tex. Crim. App. 2016).published
- People v. K.J. (In re K.J.), 18 Cal. App. 5th 1123 (Cal. Ct. App. 2018).published
- Commonwealth v. Costa, 862 N.E.2d 371 (Mass. 2007).published
- State v. Jordan, 817 N.E.2d 864 (Ohio 2004).published
- United States v. Pollins, 145 F. Supp. 3d 525 (D. Md. 2015).published
- State v. Privott, 999 A.2d 415 (N.J. 2010).published
- State v. Edmonds, 47 A.3d 737 (N.J. 2012).published
- United States v. Saddler, 275 F. App'x 549 (7th Cir. 2008).unpublished
- Parker v. Chard, 998 F. Supp. 2d 799 (D. Minn. 2014).published
- Adam England v. Commonwealth of Kentucky, No. 2022 CA 000849 (Ky. Ct. App. Nov. 2, 2023).unpublished
- State Of Louisiana In The Interest of K.B.J., 383 So. 3d 943 (La. Ct. App. 2024).published
- United States v. Benavides, 291 F. App'x 603 (5th Cir. 2008).unpublished
- P. v. Willams, No. F063696 (Cal. Ct. App. Apr. 10, 2013).unpublished
- United States v. Griffin, 589 F.3d 148 (4th Cir. 2009).published
- United States v. Hicks, 531 F.3d 555 (7th Cir. 2008).published
- Gilmore v. State, 323 S.W.3d 250 (Tex. App.—Texarkana 2010).published
- State v. Wilson, 337 S.W.3d 289 (Tex. App.—Texarkana 2011).published
- United States v. Bates, 750 F. Supp. 2d 342 (D. Mass. 2010).published
- State in Interest of PL, 81 So. 3d 983 (La. Ct. App. 2012).published
- State v. Bishop, 203 P.3d 1203 (Idaho 2009).published
- People v. Mitchell, No. F066573 (Cal. Ct. App. Mar. 12, 2014).unpublished
- United States v. McCaw, 664 F. App'x 578 (7th Cir. 2016).unpublished
- State of New Jersey Vs. Darryl J. Hunter, No. A-2641-15T3 (N.J. Super. Ct. App. Div. May 31, 2017).unpublished
- State of Iowa v. Christine Ann Kern, 831 N.W.2d 149 (Iowa 2013).published
- United States v. Norbert, 990 F.3d 968 (5th Cir. 2021).published
- K.P. v. State, 129 So. 3d 1121 (Fla. 3d DCA 2013).published
- People of Michigan v. Claudell Turner, 995 N.W.2d 857 (Mich. Ct. App. 2022).published
- United States v. Evans, 947 F. Supp. 2d 895 (E.D. Tenn. 2013).published
- United States v. Reza, No. 23-2049 (10th Cir. Feb. 13, 2024).unpublished
- United States v. Anthony H. Lindsey, 482 F.3d 1285 (11th Cir. 2007).published
- United States v. Massenburg, 654 F.3d 480 (4th Cir. 2011).published
- Bazzi v. City of Dearborn, 658 F.3d 598 (6th Cir. 2011).published
- United States v. Everett Oshae Brown, 401 F.3d 588 (4th Cir. 2005).published
- United States v. Ernest G.M. Rowland, 464 F.3d 899 (9th Cir. 2006).published
- United States v. Hal M. Atchley, 474 F.3d 840 (6th Cir. 2007).published
- United States v. Kevin Laville, 480 F.3d 187 (3d Cir. 2007).published
- United States v. Cowgill, 68 M.J. 388 (C.A.A.F. 2010).published
- United States v. Daniel Bustamante, 478 F. App'x 922 (5th Cir. 2012).unpublished
- United States v. Jerrod Abney, 496 F. App'x 248 (3d Cir. 2012).unpublished
- United States v. Sam Stallings, 513 F. App'x 161 (3d Cir. 2013).unpublished
- P. v. Andres, No. D060774 (Cal. Ct. App. Mar. 25, 2013).unpublished
- United States v. Reaves, 512 F.3d 123 (4th Cir. 2008).published
- Smith v. Commonwealth, 696 S.E.2d 211 (Va. Ct. App. 2010).published
- United States v. Torres, 534 F.3d 207 (3d Cir. 2008).published
- United States v. Whitaker, 546 F.3d 902 (7th Cir. 2008).published
- United States v. Groves, 559 F.3d 637 (7th Cir. 2009).published
- Grandberry v. State, 658 S.E.2d 161 (Ga. Ct. App. 2008).published
- Henson v. Commonwealth, 245 S.W.3d 745 (Ky. 2008).published
- M.D. ex rel. Daniels v. Smith, 504 F. Supp. 2d 1238 (M.D. Ala. 2007).published
- People v. Perreault, 782 N.W.2d 526 (Mich. Ct. App. 2010).published
- Commonwealth v. Wiley, 904 A.2d 905 (Pa. 2006).published
- Abdul-Jalil v. Commonwealth, 324 S.W.3d 433 (Ky. Ct. App. 2010).published
- Commonwealth v. Wiley, 858 A.2d 1191 (Pa. Super. Ct. 2004).published
- Segar v. State, 937 N.E.2d 917 (Ind. Ct. App. 2010).published
- John David Martinez v. State, No. 04-09-00204-CR (Tex. App.—San Antonio June 23, 2010).published
- State v. Collier, 2019-Ohio-3197.published
- State v. Cardenas-Muratalla, 319 P.3d 811 (Wash. Ct. App. 2014).published
- Commonwealth v. Gomes, 917 N.E.2d 231 (Mass. App. Ct. 2009).published
- United States v. Wilson, 995 F. Supp. 2d 455 (W.D.N.C. 2014).published
- United States v. Simmons, 560 F.3d 98 (2d Cir. 2009).published
- United States v. Hayes, 574 F. Supp. 2d 308 (W.D.N.Y. 2008).published
- Commonwealth v. MacKey, 177 A.3d 221 (Pa. Super. Ct. 2017).published
- In re K.J., No. A147478 (Cal. Ct. App. Jan. 3, 2018).published
- State of Tennessee v. Calvin Lyndell Dibrell, No. E2016-02279-CCA-R3-CD (Tenn. Crim. App. Mar. 26, 2018).published
- United States v. Ibrahim McCants, 911 F.3d 127 (3d Cir. 2018).published
- United States v. Ibrahim McCants, 920 F.3d 169 (3d Cir. 2019).published
- United States v. Ibrahim McCants, 952 F.3d 416 (3d Cir. 2020).published
- People v. Carter, 2019 IL App (1st) 170803 (Ill. App. Ct. 1st Dist. 2021).published
- State of Maine v. Timothy Barclift, 2022 ME 50, 282 A.3d 607.published
- People v. Henderson, 2013 IL 114040, 989 N.E.2d 192.published
- People of Michigan v. Anne Marie Lambert, No. 344788 (Mich. Ct. App. Nov. 21, 2019).unpublished
- United States v. Gomez, 623 F.3d 265 (5th Cir. 2010).published“The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.”
- State v. Lindsey Nichole Houghton, 384 S.W.3d 441 (Tex. App.—Fort Worth 2012).published“The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.”
- United States v. Aviles-Vega, 783 F.3d 69 (1st Cir. 2015).published
At page 270 Corroborating anonymous tips to establish reasonable suspicion351 citing casesa known informant . . . can be held responsible if her allegations turn out to be fabricated
- Commonwealth of Virginia v. William Lamont Jones, No. 0360241 (Va. Ct. App. July 16, 2024).unpublished([C]itizens who pe[r]sonally report crimes to the police thereby make themselves accountable for lodging false complaints.)
- People v. Holmes, 2019 IL App (1st) 160987.published See 529 U.S. at 268 (“a young black male standing at a particular bus stop and wearing a plaid shirt”).
- Michael Frank Lapace v. State of Florida, 257 So. 3d 588 (Fla. 2d DCA 2018).published See J.L., 529 U.S. at 271 ("The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.").
- Wayne Antonio Bland, Jr. v. Commonwealth of Virginia, 785 S.E.2d 798 (Va. Ct. App. 2016).published ([RJeasonable suspicion ... requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.)
- United States v. Stevens, 530 F.3d 714 (8th Cir. 2008).published(a known informant . . . can be held responsible if her allegations turn out to be fabricated)
- People v. Mario T., 875 N.E.2d 1241 (Ill. App. Ct. 1st Dist. 2007).published (reasonableness of official suspicion must be measured by what the officers knew before they conducted their search)
- State v. Williams, 887 A.2d 190 (N.J. Super. Ct. App. Div. 2005).published (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- State v. Allison, 559 S.E.2d 828 (N.C. Ct. App. 2002).published (there are situations in which an anonymous tip, suitably corroborated, exhibits ‘sufficient indicia of reliability to provide reasonable suspicion to make the investigatory stop’)
- In re Stumbo, 547 S.E.2d 451 (N.C. Ct. App. 2001).published (an anonymous tip alone seldom demonstrates the informant’s basis of knowledge or veracity)
- State v. Frazier, 542 S.E.2d 682 (N.C. Ct. App. 2001).published ([a]nonymous tips . . . are generally less reliable than tips from known informants and can form the basis for reasonable suspicion only if accompanied by specific indicia of reliability)
Show 188 more citing cases
- State v. Hughes, 539 S.E.2d 625 (N.C. 2000).published (there are situations in which an anonymous tip, suitably corroborated, exhibits ‘sufficient indicia of reliability to provide reasonable suspicion to make the investigatory stop’)
- James Allen Johnson v. State, 869 S.E.2d 177 (Ga. Ct. App. 2022).published “unlike a tip from a known informant whose reputation can be assessed and who can be held responsible if her allegations turn out to be fabricated, . . . an anonymous tip alone seldom demonstrates the informant's basis o…”
- United States v. Avagyan, 164 F. Supp. 3d 864 (E.D. Va. 2016).published
- Carl Richard Cook v. Rankin Cnty., No. 2012-CT-01553-SCT (Miss. Oct. 16, 2014).published
- Carl Richard Cook v. State of Mississippi, 159 So. 3d 534 (Miss. 2015).published
- People v. Turner, 219 Cal. App. 4th 151 (Cal. Ct. App. 2013).published
- Sidney v. Com., 702 S.E.2d 124 (Va. 2010).published
- State v. Taylor, 694 S.E.2d 60 (S.C. Ct. App. 2010).published
- State v. Barras, 20 So. 3d 1100 (La. Ct. App. 2009).published
- Baptiste v. State, 995 So. 2d 285 (Fla. 2008).published
- People v. Rollins, 892 N.E.2d 21 (Ill. App. Ct. 4th Dist. 2008).published
- People v. Snyder, 904 N.E.2d 625 (Ill. App. Ct. 4th Dist. 2009).published
- Johnson v. Williams, 584 F. Supp. 2d 97 (D.D.C. 2008).published
- People v. Rhinehart, 961 N.E.2d 933 (Ill. App. Ct. 1st Dist. 2011).published
- United States v. Freeman, 735 F.3d 92 (2d Cir. 2013).published
- Tazarius Cooper v. State of Mississippi, 145 So. 3d 1164 (Miss. 2014).published
- People v. Pimentel, No. C075824 (Cal. Ct. App. Dec. 9, 2014).unpublished
- People v. Latchman, No. B253042 (Cal. Ct. App. Dec. 17, 2014).unpublished
- United States v. Sanchez, 817 F.3d 38 (1st Cir. 2016).published
- United States v. Zachary Foster, 824 F.3d 84 (4th Cir. 2016).published
- United States v. James Bryant, Jr., 654 F. App'x 622 (4th Cir. 2016).unpublished
- State of Minnesota v. Henry James Johnson, No. A15-1398 (Minn. Ct. App. Aug. 1, 2016).unpublished
- United States v. Kevelin Noel, 659 F. App'x 284 (6th Cir. 2016).unpublished
- Ames v. State, 153 A.3d 899 (Md. Ct. Spec. App. 2017).published
- United States v. Gerald Jackson, 700 F. App'x 411 (6th Cir. 2017).unpublished
- Everett Miles v. United States, 181 A.3d 633 (D.C. 2018).published
- State of Washington v. Ismael M. Tarango, 434 P.3d 77 (Wash. Ct. App. 2019).published
- Birdie Jean Jackson v. State, No. 02-19-00370-CR (Tex. App.—Fort Worth Apr. 22, 2021).unpublished
- United States v. Gaines, No. 19-3177 (10th Cir. May 25, 2021).unpublished
- Simms v. State, 51 So. 3d 1264 (Fla. 2d DCA 2011).published
- Furr v. State, 499 S.W.3d 872 (Tex. Crim. App. 2016).published
- People v. K.J. (In re K.J.), 18 Cal. App. 5th 1123 (Cal. Ct. App. 2018).published
- Commonwealth v. Gomes, 937 N.E.2d 13 (Mass. 2010).published
- Commonwealth v. Anderson, 963 N.E.2d 704 (Mass. 2012).published
- State v. Basil, 998 A.2d 472 (N.J. 2010).published
- United States v. Saddler, 275 F. App'x 549 (7th Cir. 2008).unpublished
- State Of Louisiana In The Interest of K.B.J., 383 So. 3d 943 (La. Ct. App. 2024).published
- United States v. Erick Coleman, 383 F. App'x 180 (3d Cir. 2010).unpublished
- United States v. Roy Hairston, 402 F. App'x 84 (6th Cir. 2010).unpublished
- United States v. Monya Townsend, 472 F. App'x 625 (9th Cir. 2012).unpublished
- United States v. Jones, 700 F.3d 615 (1st Cir. 2012).published
- P. v. Willams, No. F063696 (Cal. Ct. App. Apr. 10, 2013).unpublished
- State v. Smith, No. 28,402 (N.M. Ct. App. Nov. 9, 2009).unpublished
- United States v. Griffin, 589 F.3d 148 (4th Cir. 2009).published
- United States v. Hicks, 531 F.3d 555 (7th Cir. 2008).published
- United States v. Janvier, 798 F. Supp. 2d 362 (D. Mass. 2011).published
- Gilmore v. State, 323 S.W.3d 250 (Tex. App.—Texarkana 2010).published
- State v. Wilson, 337 S.W.3d 289 (Tex. App.—Texarkana 2011).published
- United States v. Bates, 750 F. Supp. 2d 342 (D. Mass. 2010).published
- In re A.J. M.-b, 713 S.E.2d 104 (N.C. Ct. App. 2011).published
- State in Interest of PL, 81 So. 3d 983 (La. Ct. App. 2012).published
- State v. Bishop, 203 P.3d 1203 (Idaho 2009).published
- People v. Mitchell, No. F066573 (Cal. Ct. App. Mar. 12, 2014).unpublished
- State v. Maitland, 2011-Ohio-6244.published
- Com. v. Leon, J., No. 2391 EDA 2013 (Pa. Super. Ct. Dec. 30, 2014).unpublished
- United States v. McCaw, 664 F. App'x 578 (7th Cir. 2016).unpublished
- Nathan P. Jackson v. United States, 157 A.3d 1259 (D.C. 2017).published
- State of New Jersey Vs. Darryl J. Hunter, No. A-2641-15T3 (N.J. Super. Ct. App. Div. May 31, 2017).unpublished
- State of Iowa v. Christine Ann Kern, 831 N.W.2d 149 (Iowa 2013).published
- Conway Spence Hyman v. Commonwealth of Virginia, No. 0519181 (Va. Ct. App. Oct. 22, 2019).unpublished
- United States v. Norbert, 990 F.3d 968 (5th Cir. 2021).published
- People v. Benbow, 193 A.D.3d 869 (N.Y. App. Div. 2d Dep't 2021).published
- K.P. v. State, 129 So. 3d 1121 (Fla. 3d DCA 2013).published
- People v. Ponce, 203 A.D.3d 1628 (N.Y. App. Div. 4th Dep't 2022).published
- People of Michigan v. Claudell Turner, 995 N.W.2d 857 (Mich. Ct. App. 2022).published
- State v. Batt, 2010 WI App 155, 793 N.W.2d 104.published
- United States v. Evans, 947 F. Supp. 2d 895 (E.D. Tenn. 2013).published
- United States v. Reza, No. 23-2049 (10th Cir. Feb. 13, 2024).unpublished
- United States v. Bryant, No. 2025-0097 (D.D.C. Dec. 4, 2025).published
- People v. Owens, 249 A.D.3d 753 (N.Y. App. Div. 2d Dep't 2026).published
- United States v. Chavez, 660 F.3d 1215 (10th Cir. 2011).published
- Commonwealth v. MacKey, 177 A.3d 221 (Pa. Super. Ct. 2017).published
- State of Tennessee v. Calvin Lyndell Dibrell, No. E2016-02279-CCA-R3-CD (Tenn. Crim. App. Mar. 26, 2018).published
- United States v. Watson, 900 F.3d 892 (7th Cir. 2018).published
- Shuler v. State, 346 A.3d 245 (Md. Ct. Spec. App. 2025).published
- United States v. Tyrone Harris, 747 F.3d 1013 (8th Cir. 2014).published
At page 272 Defining reliability for reasonable suspicion from anonymous tips355 citing cases“the reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.”
- Martinez v. State, 348 S.W.3d 919 (Tex. Crim. App. 2011).published But see Florida v. J.L., 529 U.S. 266, 275 , 120 S.Ct. 1375 , 146 L.Ed.2d 254 (2000) (Kennedy, J., concurring) (faulting the police officer for acting on an anonymous tip and pointing out that "[t]he record does not show whether some notat…
- Lewaco Leyultee Clay v. Commonwealth of Kentucky, No. 2020 CA 001525 (Ky. Ct. App. Dec. 1, 2022).unpublished (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- People of Michigan v. Victoria Catherine Pagano, 967 N.W.2d 590 (Mich. 2021).published (The reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.)
- Jamar Rasaan Alford v. Commonwealth of Virginia, No. 1775192 (Va. Ct. App. Dec. 15, 2020).unpublished For all intents and purposes as to Officer Keys’s knowledge, then, the information provided to him in the dispatch was from an unidentified source.4 As such, the United States Supreme Court’s decision in Florida v. J.L., 529 U.S. 266 (2000…
- People v. Holmes, 2019 IL App (1st) 160987.published See 529 U.S. at 268 (“a young black male standing at a particular bus stop and wearing a plaid shirt”).
- Krysta Sutterfield v. City of Milwaukee, 751 F.3d 542 (7th Cir. 2014).published (Firearms are dangerous, and extraordinary dangers some- times justify unusual precautions.)
- Dennis Johnson v. State, No. 01-10-00134-CR, 2011 WL 5428969 (Tex. App.—Houston [1st Dist.] Nov. 10, 2011).published (The reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.)
- Martinez, John David, No. PD-1238-10 (Tex. Crim. App. June 29, 2011).published (reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality . . ..)
- People v. Mario T., 875 N.E.2d 1241 (Ill. App. Ct. 1st Dist. 2007).published (reasonableness of official suspicion must be measured by what the officers knew before they conducted their search)
- United States v. Jervis Lavern Goodrich, 450 F.3d 552 (3d Cir. 2006).published (The reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.)
Show 187 more citing cases
- State v. Hopkins, 117 P.3d 377 (Wash. Ct. App. 2005).published “The reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.”
- United States v. Kenneth King, 227 F.3d 732 (6th Cir. 2000).published (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- United States v. Ubiles, No. 00-3091 (3d Cir. Aug. 17, 2000). (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- Commonwealth v. Hicks, M., 208 A.3d 916 (Pa. 2019).published “a second major argument advanced by florida and the united states as amicus is, in essence, that the standard terry analysis should be modified to license a 'firearm exception.' ... we decline to adopt this position.”
- United States v. Avagyan, 164 F. Supp. 3d 864 (E.D. Va. 2016).published
- Carl Richard Cook v. Rankin Cnty., No. 2012-CT-01553-SCT (Miss. Oct. 16, 2014).published
- Carl Richard Cook v. State of Mississippi, 159 So. 3d 534 (Miss. 2015).published
- United States v. Larry McKnight, 469 F. App'x 349 (5th Cir. 2012).unpublished
- United States v. Dwayne Parker, 467 F. App'x 120 (3d Cir. 2012).unpublished
- People v. Turner, 219 Cal. App. 4th 151 (Cal. Ct. App. 2013).published
- Sidney v. Com., 702 S.E.2d 124 (Va. 2010).published
- United States v. Silveus, 542 F.3d 993 (3d Cir. 2008).published
- State v. Barras, 20 So. 3d 1100 (La. Ct. App. 2009).published
- Baptiste v. State, 995 So. 2d 285 (Fla. 2008).published
- People v. Horton, 767 N.W.2d 672 (Mich. Ct. App. 2009).published
- United States v. Williams, 804 F. Supp. 2d 659 (M.D. Tenn. 2011).published
- People v. Snyder, 904 N.E.2d 625 (Ill. App. Ct. 4th Dist. 2009).published
- Martinez v. State, 318 S.W.3d 24 (Tex. App.—San Antonio 2010).published
- In re S.B., 44 A.3d 948 (D.C. 2012).published
- Johnson v. Williams, 584 F. Supp. 2d 97 (D.D.C. 2008).published
- People v. Rhinehart, 961 N.E.2d 933 (Ill. App. Ct. 1st Dist. 2011).published
- United States v. Freeman, 735 F.3d 92 (2d Cir. 2013).published
- State v. Kevin Gamble (071234), 95 A.3d 188 (N.J. 2014).published
- State v. Rodriguez, No. S-13-062 (Neb. Aug. 29, 2014).published
- State of Iowa v. Clifford Lynn McNeal, No. 13-1229 (Iowa Ct. App. Oct. 29, 2014).published
- United States v. Shawn Lowe, 791 F.3d 424 (3d Cir. 2015).published
- State v. Ebert, 2015-Ohio-5012.published
- Ames v. State, 153 A.3d 899 (Md. Ct. Spec. App. 2017).published
- State v. Stanage, 2017 S.D. 12, 893 N.W.2d 522.published
- Thomas Pinner v. State of Indiana, 74 N.E.3d 226 (Ind. 2017).published
- State of Iowa v. Leon Kooima, 833 N.W.2d 202 (Iowa 2013).published
- Everett Miles v. United States, 181 A.3d 633 (D.C. 2018).published
- Ernest Foster, Sr. v. Jeremy Hellawell, 908 F.3d 1204 (9th Cir. 2018).published
- State of Washington v. Ismael M. Tarango, 434 P.3d 77 (Wash. Ct. App. 2019).published
- Birdie Jean Jackson v. State, No. 02-19-00370-CR (Tex. App.—Fort Worth Apr. 22, 2021).unpublished
- United States v. Gaines, No. 19-3177 (10th Cir. May 25, 2021).unpublished
- State v. Tidwell (Slip Opinion), 2021-Ohio-2072, 175 N.E.3d 527.published
- Simms v. State, 51 So. 3d 1264 (Fla. 2d DCA 2011).published
- People v. Carter, 2021 IL 125954, 190 N.E.3d 224.published
- People v. K.J. (In re K.J.), 18 Cal. App. 5th 1123 (Cal. Ct. App. 2018).published
- Commonwealth v. Mubdi, 923 N.E.2d 1004 (Mass. 2010).published
- Commonwealth v. Gomes, 937 N.E.2d 13 (Mass. 2010).published
- In re D.W., 921 N.E.2d 1114 (Ohio Ct. App. 2d Dist. 2009).published
- United States v. Pollins, 145 F. Supp. 3d 525 (D. Md. 2015).published
- State v. Basil, 998 A.2d 472 (N.J. 2010).published
- State v. Edmonds, 47 A.3d 737 (N.J. 2012).published
- United States v. Rose, 48 F.4th 297 (5th Cir. 2022).published
- Parker v. Chard, 998 F. Supp. 2d 799 (D. Minn. 2014).published
- State Of Louisiana In The Interest of K.B.J., 383 So. 3d 943 (La. Ct. App. 2024).published
- United States v. Benavides, 291 F. App'x 603 (5th Cir. 2008).unpublished
- William M. Smith, Jr. v. State, No. 12-07-00214-CR (Tex. App.—Tyler Sept. 3, 2008).published
- United States v. Erick Coleman, 383 F. App'x 180 (3d Cir. 2010).unpublished
- United States v. Roy Hairston, 402 F. App'x 84 (6th Cir. 2010).unpublished
- United States v. Jones, 700 F.3d 615 (1st Cir. 2012).published
- State v. Smith, No. 28,402 (N.M. Ct. App. Nov. 9, 2009).unpublished
- United States v. Griffin, 589 F.3d 148 (4th Cir. 2009).published
- United States v. Hicks, 531 F.3d 555 (7th Cir. 2008).published
- United States v. Janvier, 798 F. Supp. 2d 362 (D. Mass. 2011).published
- Gilmore v. State, 323 S.W.3d 250 (Tex. App.—Texarkana 2010).published
- United States v. Bates, 750 F. Supp. 2d 342 (D. Mass. 2010).published
- In re A.J. M.-b, 713 S.E.2d 104 (N.C. Ct. App. 2011).published
- State v. Maitland, 2011-Ohio-6244.published
- Com. v. Leon, J., No. 2391 EDA 2013 (Pa. Super. Ct. Dec. 30, 2014).unpublished
- United States v. McCaw, 664 F. App'x 578 (7th Cir. 2016).unpublished
- Nathan P. Jackson v. United States, 157 A.3d 1259 (D.C. 2017).published
- State of New Jersey Vs. Darryl J. Hunter, No. A-2641-15T3 (N.J. Super. Ct. App. Div. May 31, 2017).unpublished
- United States v. Norbert, 990 F.3d 968 (5th Cir. 2021).published
- People v. Benbow, 193 A.D.3d 869 (N.Y. App. Div. 2d Dep't 2021).published
- K.P. v. State, 129 So. 3d 1121 (Fla. 3d DCA 2013).published
- People v. Ponce, 203 A.D.3d 1628 (N.Y. App. Div. 4th Dep't 2022).published
- People of Michigan v. Claudell Turner, 995 N.W.2d 857 (Mich. Ct. App. 2022).published
- State v. Batt, 2010 WI App 155, 793 N.W.2d 104.published
- United States v. Evans, 947 F. Supp. 2d 895 (E.D. Tenn. 2013).published
- United States v. Bryant, No. 2025-0097 (D.D.C. Dec. 4, 2025).published
- People v. Owens, 249 A.D.3d 753 (N.Y. App. Div. 2d Dep't 2026).published
- United States v. Massenburg, 654 F.3d 480 (4th Cir. 2011).published
- United States v. Jerrod Abney, 496 F. App'x 248 (3d Cir. 2012).unpublished
- P. v. Andres, No. D060774 (Cal. Ct. App. Mar. 25, 2013).unpublished
- Smith v. Commonwealth, 696 S.E.2d 211 (Va. Ct. App. 2010).published
- United States v. Whitaker, 546 F.3d 902 (7th Cir. 2008).published
- Abdul-Jalil v. Commonwealth, 324 S.W.3d 433 (Ky. Ct. App. 2010).published
- Segar v. State, 937 N.E.2d 917 (Ind. Ct. App. 2010).published
- John David Martinez v. State, No. 04-09-00204-CR (Tex. App.—San Antonio June 23, 2010).published
- State v. Collier, 2019-Ohio-3197.published
- State v. Cardenas-Muratalla, 319 P.3d 811 (Wash. Ct. App. 2014).published
- Commonwealth v. Gomes, 917 N.E.2d 231 (Mass. App. Ct. 2009).published
- United States v. Wilson, 995 F. Supp. 2d 455 (W.D.N.C. 2014).published
- United States v. Quezada-Enriquez, 567 F.3d 1228 (10th Cir. 2009).published
- United States v. Johnson, 620 F.3d 685 (6th Cir. 2010).published
- United States v. Datcu, 627 F.3d 1074 (8th Cir. 2010).published
- United States v. Corey Roberson, No. 11-11167 (5th Cir. Nov. 6, 2012).unpublished
- State of Tennessee v. Jerry Lee Hanning - Concurring, No. E2006-02196-SC-R11-CD (Tenn. Oct. 20, 2009).published
- State of Tennessee v. Jerry Lee Hanning, 296 S.W.3d 44 (Tenn. 2009).published
- State v. Peele, 675 S.E.2d 682 (N.C. Ct. App. 2009).published
- State v. Johnson, 693 S.E.2d 711 (N.C. Ct. App. 2010).published
- Regalado v. State, 25 So. 3d 600 (Fla. 4th DCA 2009).published
- State of Minnesota v. Chad Michael Smith, No. A13-1296 (Minn. Ct. App. July 14, 2014).unpublished
- State v. Nebbitt, 455 S.W.3d 79 (Mo. Ct. App. 2014).published
- State of Iowa v. Craig E. Harrison, 846 N.W.2d 362 (Iowa 2014).published
- State v. Cunningham, 2014-Ohio-1924.published
- State v. Robinson, 2014-Ohio-579.published
- State of Arizona v. Ronald James Sisco II, 359 P.3d 1 (Ariz. Ct. App. 2015).published
- Edward Morgan, Jr. v. United States, 121 A.3d 1235 (D.C. 2015).published
- Michael Garrison Boone v. State, No. 10-12-00274-CR (Tex. App.—Waco Nov. 21, 2013).unpublished
- Chris Furr v. State, No. 13-14-00287-CR, 2015 WL 307757 (Tex. App.—Corpus Christi Jan. 22, 2015).unpublished
- Pittman, Susan Renee v. State, No. 05-12-00098-CR (Tex. App.—Dallas July 3, 2013).unpublished
- People v. Lopez, 2013 IL App (1st) 111819, 996 N.E.2d 212.published
- Commonwealth of Virginia v. Sharonda Monique Gaiters, No. 1832152 (Va. Ct. App. Mar. 22, 2016).unpublished
- United States v. Spencer, 646 F. App'x 6 (2d Cir. 2016).unpublished
- State v. Ray Burgess, 138 A.3d 195 (R.I. 2016).published
- State of Tennessee v. June Anne Wascher, No. E2015-00961-CCA-R3-CD (Tenn. Crim. App. June 6, 2016).published
- Leroy Duffie v. City of Lincoln, 834 F.3d 877 (8th Cir. 2016).published
- People v. Orndorff, No. A141994 (Cal. Ct. App. Sept. 26, 2016).unpublished
- Furr, Chris, No. PD-0212-15 (Tex. Crim. App. Feb. 26, 2015).unpublished
- Robert Lafayette Walker v. State, No. 12-15-00128-CR (Tex. App.—Tyler Aug. 17, 2015).published
- Michael Grace v. State, No. 03-15-00221-CR (Tex. App.—Austin June 4, 2015).published
- State v. Mangum, 795 S.E.2d 106 (N.C. Ct. App. 2016).published
- People v. Thomas, 2016 IL App (1st) 141040.published
- Daniels v. State, 208 So. 3d 1223 (Fla. 2d DCA 2017).published
- Charles Beal, Jr. v. James Beller, 847 F.3d 897 (7th Cir. 2017).published
- State v. Lurdes Rosario (077420) (Monmouth & Statewide), 162 A.3d 249 (N.J. 2017).published
- State v. Pokoiski, No. 1610003340 (Del. Super. Ct. June 19, 2017).published
- State of New Jersey Vs. Dwight M. Nelson, No. A-2958-15T4 (N.J. Super. Ct. App. Div. Aug. 15, 2017).unpublished
- Com. v. Mackey, S., No. 1460 EDA 2015 (Pa. Super. Ct. Dec. 20, 2017).published
- Zachariah Ferris Houghtaling v. State, No. 10-17-00038-CR (Tex. App.—Waco Aug. 15, 2018).unpublished
- People v. Lopez, 2018 IL App (1st) 153331.published
- People v. Holz, 2018 NY Slip Op 8763 (N.Y. App. Div. 4th Dep't 2018).published
- State v. Henderson, 2019-Ohio-1974.published
- Daniel Bartolo Hernandez v. State, No. 02-18-00120-CR (Tex. App.—Fort Worth Aug. 15, 2019).unpublished
- State of New Jersey Vs. Christoph C. Jones, No. A-3172-16T1 (N.J. Super. Ct. App. Div. June 25, 2018).unpublished
- State of Iowa v. Komut Mai, 939 N.W.2d 643 (Iowa Ct. App. 2019).published
- United States v. Chavez Antwon Hunter, No. 16-16982 (11th Cir. Jan. 9, 2020).unpublished
- United States v. Toddrey Willie Bruce, 977 F.3d 1112 (11th Cir. 2020).published
- State of Iowa v. Patrick Bracy, 957 N.W.2d 34 (Iowa Ct. App. 2021).published
- People v. Spain, 2019 IL App (1st) 163184 (Ill. App. Ct. 1st Dist. 2021).published
- State v. Saggers, 332 P.3d 1034 (Wash. Ct. App. 2014).published
- State v. Flowers, 420 S.W.3d 579 (Mo. Ct. App. 2013).published
- State v. Royster, 867 S.E.2d 204 (N.C. Ct. App. 2021).published
- People v. Sampson, 68 A.D.3d 1455 (N.Y. App. Div. 3d Dep't 2009).published
- Commonwealth v. Arias, 963 N.E.2d 100 (Mass. App. Ct. 2012).published
- United States v. Alvarez, 40 F.4th 339 (5th Cir. 2022).published
- United States v. Knox, 79 F. Supp. 3d 1219 (D. Kan. 2015).published
- United States v. Gonzalez, 111 F. Supp. 3d 416 (S.D.N.Y. 2015).published
- State v. Hathaway, 120 A.3d 155 (N.J. 2015).published
- State of Maine v. Joshua Lovell, 2022 ME 49, 281 A.3d 651.published
- United States v. Shaw, 874 F. Supp. 2d 13 (D. Mass. 2012).published
- Floyd v. City of New York, 959 F. Supp. 2d 540 (S.D.N.Y. 2013).published
- State v. Harwood, 727 S.E.2d 891 (N.C. Ct. App. 2012).published
- State v. Coleman, 743 S.E.2d 62 (N.C. Ct. App. 2013).published
- State v. Wright, 892 S.E.2d 253 (N.C. Ct. App. 2023).published
- Jeffrey Antonio Barlow v. Commonwealth of Virginia, No. 1133222 (Va. Ct. App. Jan. 9, 2024).unpublished
- State of New Jersey v. Ezell Miller, No. A-2297-21 (N.J. Super. Ct. App. Div. Feb. 1, 2024).unpublished
- State v. Napoleao Pires, 316 A.3d 701 (R.I. 2024).published
- Lewis v. State, 233 A.3d 86 (Md. 2020).published
- Gray v. Evanston of, No. 1:23-cv-01931 (N.D. Ill. July 22, 2024).
- Commonwealth v. Pierre a. Sertyl., 101 Mass. App. Ct. 836 (Mass. App. Ct. 2022).published
- McCurdy v. State, No. 185, 2024 (Del. Mar. 10, 2025).published
- Senque Wright v. State of Mississippi, 334 So. 3d 1115 (Miss. 2021).published
- Sekema Gentles v. Borough of Pottstown, No. 22-2925 (3d Cir. July 24, 2025).unpublished
- Commonwealth v. Luis Morales, 272 N.E.3d 629 (Mass. App. Ct. 2025).published
- People v. Leighton R., 2025 NY Slip Op 06534 (N.Y. 2025).published
- People v. Robinson, 246 A.D.3d 1388 (N.Y. App. Div. 4th Dep't 2026).published
- The People of the State of Colorado, In the Interest of T.J.W., Juv.-Appellee L.C.W. & D.W. & Concerning, 2026 CO 38, 589 P.3d 905.published
- United States v. Williams, 608 F. Supp. 2d 325 (E.D.N.Y. 2008).published
- State v. Robinson, 2010 WI 80, 786 N.W.2d 463.published
- Commonwealth v. MacKey, 177 A.3d 221 (Pa. Super. Ct. 2017).published
- Commonwealth v. Famania, 946 N.E.2d 135 (Mass. App. Ct. 2011).published
- United States v. Harger, 313 F. Supp. 3d 1082 (N.D. Cal. 2018).published
- People v. Barbarich, 807 N.W.2d 56 (Mich. Ct. App. 2011).published
- State of Maine v. Timothy Barclift, 2022 ME 50, 282 A.3d 607.published
- Shuler v. State, 346 A.3d 245 (Md. Ct. Spec. App. 2025).published
- People v. Henderson, 2013 IL 114040, 989 N.E.2d 192.published
- People of Michigan v. Anne Marie Lambert, No. 344788 (Mich. Ct. App. Nov. 21, 2019).unpublished
- State of Tennessee v. Guy Alvin Williamson, 368 S.W.3d 468 (Tenn. 2012).published
- United States v. Kareem Cusick, 559 F. App'x 790 (11th Cir. 2014).unpublished
- Memorandum Opinion v. One (1)2004 Lincoln Navigator, 496 S.W.3d 97 (Tex. App.—Corpus Christi 2014).published
- Melvin E. Jackson v. United States, 109 A.3d 1105 (D.C. 2015).published
- People v. Bailey, 2018 NY Slip Op 5856 (N.Y. App. Div. 2d Dep't 2018).published
- United States v. Fausto Lopez, 907 F.3d 472 (7th Cir. 2018).published
- State v. Harris, 21 So. 3d 437 (La. Ct. App. 2009).published
- Hill v. Dewey, No. 7:18-cv-00021 (M.D. Ga. Apr. 6, 2020).
- United States v. Reyes, 225 F. App'x 699 (9th Cir. 2007).unpublished“An accurate description of a subject’s readily observable location and appearance ... does not show that the tipster has knowledge of concealed criminal activity.”
- United States v. Ayala, 169 F. App'x 717 (3d Cir. 2006).unpublished“The reasonable suspicion here at issue requires that a tip be rehable in its assertion of illegality, not just in its tendency to identify a determinate person.”
- State v. Johnson, 806 So. 2d 647 (La. 2002).published“The reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.”
- United States v. Tyrone Harris, 747 F.3d 1013 (8th Cir. 2014).published“Firearms are dangerous, and extraordinary dangers sometimes justify unusual precautions.”
- United States v. Aviles-Vega, 783 F.3d 69 (1st Cir. 2015).published
- State v. Lindsey Nichole Houghton, 384 S.W.3d 441 (Tex. App.—Fort Worth 2012).published
At page 268 Anonymous tips insufficient to justify stop and frisk270 citing cases“a young black male standing at a particular bus stop and wearing a plaid shirt was carrying a gun.”
- People of Michigan v. Victoria Catherine Pagano, 967 N.W.2d 590 (Mich. 2021).published See J L, 529 US at 272 (“The reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.”).
- Jamar Rasaan Alford v. Commonwealth of Virginia, No. 1775192 (Va. Ct. App. Dec. 15, 2020).unpublished (The question presented in this case is whether an anonymous tip that a person is carrying a gun is, without more, sufficient to justify a police officer’s stop . . . of that person. We hold that it is not.)
- People v. Holmes, 2019 IL App (1st) 160987.published (a young black male standing at a particular bus stop and wearing a plaid shirt)
- Com. v. Vazquez, J., No. 3618 EDA 2017 (Pa. Super. Ct. Oct. 5, 2018).unpublished“Apart from the tip, the officers had no reason to suspect any of the three of illegal conduct”
- Wayne Antonio Bland, Jr. v. Commonwealth of Virginia, 785 S.E.2d 798 (Va. Ct. App. 2016).published Id. at 271-72, 120 S.Ct. at 1378-80 (“[RJeasonable suspicion ... requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.”).
- Commonwealth of Virginia v. Jermaine Durell Spence, No. 1515141 (Va. Ct. App. Jan. 9, 2015).unpublished Id. at 271-72 (“[R]easonable suspicion . . . requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person.”).
- State v. Williams, 887 A.2d 190 (N.J. Super. Ct. App. Div. 2005).published See, e.g., Florida v. J.L., supra, 529 U.S. at 271, 120 S.Ct. at 1379 , 146 L.Ed. 2d at 260-61 ("The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search."); United States v. Sh…
- United States v. Mitchell, 388 F. App'x 328 (4th Cir. 2010).unpublished
- Carl Richard Cook v. Rankin Cnty., No. 2012-CT-01553-SCT (Miss. Oct. 16, 2014).published
- Carl Richard Cook v. State of Mississippi, 159 So. 3d 534 (Miss. 2015).published
Show 180 more citing cases
- United States v. Michael Delow Medlock, 146 F. App'x 470 (11th Cir. 2005).unpublished
- Kohler v. Englade, 470 F.3d 1104 (5th Cir. 2006).published
- United States v. Martinez, 486 F.3d 855 (5th Cir. 2007).published
- United States v. Darius Heard, 367 F.3d 1275 (11th Cir. 2004).published
- United States v. Smith, 386 F. App'x 399 (4th Cir. 2010).unpublished
- United States v. Johnson, 364 F.3d 1185 (10th Cir. 2004).published
- United States v. Williams, 403 F.3d 1188 (10th Cir. 2005).published
- United States v. Hauk, 412 F.3d 1179 (10th Cir. 2005).published
- United States v. Brown, 496 F.3d 1070 (10th Cir. 2007).published
- United States v. Copening, 506 F.3d 1241 (10th Cir. 2007).published
- United States v. Holmes Jr., Wendell, 360 F.3d 1339 (D.C. Cir. 2004).published
- United States v. Monteiro, 447 F.3d 39 (1st Cir. 2006).published
- United States v. Larry McKnight, 469 F. App'x 349 (5th Cir. 2012).unpublished
- United States v. Dwayne Parker, 467 F. App'x 120 (3d Cir. 2012).unpublished
- United States v. John Michael Perkins, 363 F.3d 317 (4th Cir. 2004).published
- United States Gov't of the Virgin Islands v. Ernie Ritter Reggy Ritter Dale Ritter, 416 F.3d 256 (3d Cir. 2005).published
- United States v. Kareem Brown, 448 F.3d 239 (3d Cir. 2006).published
- United States v. Ricky A. Caruthers, 458 F.3d 459 (6th Cir. 2006).published
- United States v. Abdul R. Muhammad, 463 F.3d 115 (2d Cir. 2006).published
- United States v. James Edward Elston, Jr., 479 F.3d 314 (4th Cir. 2007).published
- United States v. Vamond Elmore, 482 F.3d 172 (2d Cir. 2007).published
- United States v. Conner, 699 F.3d 1225 (10th Cir. 2012).published
- Jermaine Sutton v. Metro. Gov't of Nashville, 700 F.3d 865 (6th Cir. 2012).published
- David Evans v. Patrick Baker, 703 F.3d 636 (4th Cir. 2012).published
- United States v. Talvin Lawing, 703 F.3d 229 (4th Cir. 2012).published
- United States v. Shawn Lowe, 525 F. App'x 167 (3d Cir. 2013).unpublished
- United States v. Bell, 318 F. App'x 225 (4th Cir. 2009).unpublished
- United States v. Benjamin Goss, 537 F. App'x 276 (4th Cir. 2013).unpublished
- People v. Turner, 219 Cal. App. 4th 151 (Cal. Ct. App. 2013).published
- Sidney v. Com., 702 S.E.2d 124 (Va. 2010).published
- State v. Herrington, 961 So. 2d 1271 (La. Ct. App. 2007).published
- State v. Taylor, 694 S.E.2d 60 (S.C. Ct. App. 2010).published
- United States v. Silveus, 542 F.3d 993 (3d Cir. 2008).published
- United States v. Crandell, 509 F. Supp. 2d 435 (D.N.J. 2007).published
- Commonwealth v. Priddy, 184 S.W.3d 501 (Ky. 2005).published
- Cross v. State, 884 A.2d 1236 (Md. Ct. Spec. App. 2005).published
- State v. Barras, 20 So. 3d 1100 (La. Ct. App. 2009).published
- Baptiste v. State, 995 So. 2d 285 (Fla. 2008).published
- State v. Patton, 2006 WI App 235, 724 N.W.2d 347.published
- People v. Horton, 767 N.W.2d 672 (Mich. Ct. App. 2009).published
- State v. Torelli, 931 A.2d 337 (Conn. App. Ct. 2007).published
- Kellems v. State, 816 N.E.2d 421 (Ind. Ct. App. 2004).published
- State v. Crawley, 901 A.2d 924 (N.J. 2006).published
- People v. Long, 861 N.E.2d 335 (Ill. App. Ct. 2d Dist. 2007).published
- People v. Rollins, 892 N.E.2d 21 (Ill. App. Ct. 4th Dist. 2008).published
- People v. Miller, 824 N.E.2d 1080 (Ill. App. Ct. 1st Dist. 2005).published
- United States v. Williams, 804 F. Supp. 2d 659 (M.D. Tenn. 2011).published
- United States v. Wali, 811 F. Supp. 2d 1276 (N.D. Tex. 2011).published
- People v. Snyder, 904 N.E.2d 625 (Ill. App. Ct. 4th Dist. 2009).published
- Lowry v. Gutierrez, 129 Cal. App. 4th 926 (Cal. Ct. App. 2005).published
- People v. Jordan, 121 Cal. App. 4th 544 (Cal. Ct. App. 2004).published
- People v. Lindsey, 148 Cal. App. 4th 1390 (Cal. Ct. App. 2007).published
- Garcia v. Commonwealth, 335 S.W.3d 444 (Ky. Ct. App. 2010).published
- Collins v. Commonwealth, 142 S.W.3d 113 (Ky. 2004).published
- Martinez v. State, 318 S.W.3d 24 (Tex. App.—San Antonio 2010).published
- In re S.B., 44 A.3d 948 (D.C. 2012).published
- Miller v. State, 25 A.3d 768 (Del. 2011).published
- Commonwealth v. Marr, 250 S.W.3d 624 (Ky. 2008).published
- Johnson v. Williams, 584 F. Supp. 2d 97 (D.D.C. 2008).published
- United States v. Forte, 412 F. Supp. 2d 258 (W.D.N.Y. 2006).published
- United States v. Andrade, 502 F. Supp. 2d 173 (D. Mass. 2007).published
- State v. Morales, 2005-NMCA-027, 107 P.3d 513.published
- United States v. Salinas, 665 F. Supp. 2d 717 (W.D. Tex. 2009).published
- Holloway v. Vargas, 535 F. Supp. 2d 1219 (D. Kan. 2008).published
- People v. Rhinehart, 961 N.E.2d 933 (Ill. App. Ct. 1st Dist. 2011).published
- United States v. Woods, 443 F. Supp. 2d 1374 (M.D. Ala. 2006).published
- State v. Prendergast, 83 P.3d 714 (Haw. 2004).published
- People v. Dolly, 150 P.3d 693 (Cal. 2007).published
- United States v. Freeman, 735 F.3d 92 (2d Cir. 2013).published
- United States v. Monterrio Woods, 747 F.3d 552 (8th Cir. 2014).published
- United States v. Stubblefield, 931 F. Supp. 2d 118 (D.D.C. 2013).published
- Steven O. Dale v. Anthony Ciccone, 760 S.E.2d 466 (W. Va. 2014).published
- Steven O. Dale v. Anthony Ciccone, No. 13-0821 (W. Va. July 18, 2014).
- State v. Kevin Gamble (071234), 95 A.3d 188 (N.J. 2014).published
- United States v. Andre Williams, 731 F.3d 678 (7th Cir. 2013).published
- Tazarius Cooper v. State of Mississippi, 145 So. 3d 1164 (Miss. 2014).published
- State v. Rodriguez, No. S-13-062 (Neb. Aug. 29, 2014).published
- State of Missouri v. Nicholas Carr, 441 S.W.3d 166 (Mo. Ct. App. 2014).published
- State of Iowa v. Clifford Lynn McNeal, No. 13-1229 (Iowa Ct. App. Oct. 29, 2014).published
- Steven Stiegel v. Twp. of Peters, 600 F. App'x 60 (3d Cir. 2014).unpublished
- People v. Pimentel, No. C075824 (Cal. Ct. App. Dec. 9, 2014).unpublished
- People v. Latchman, No. B253042 (Cal. Ct. App. Dec. 17, 2014).unpublished
- State v. Jarquis D. Jackson, No. 05-14-00279-CR (Tex. App.—Dallas Jan. 22, 2015).unpublished
- State v. Jarquis D. Jackson, No. 05-14-00278-CR (Tex. App.—Dallas Jan. 22, 2015).unpublished
- United States v. Shawn Lowe, 791 F.3d 424 (3d Cir. 2015).published
- Srisavath v. City of Brentwood, 243 F. App'x 909 (6th Cir. 2007).unpublished
- Ewing v. City of Stockton, 588 F.3d 1218 (9th Cir. 2009).published
- People v. Lomax, 2012 IL App (1st) 103016, 975 N.E.2d 115.published
- State v. Ebert, 2015-Ohio-5012.published
- United States v. Sanchez, 817 F.3d 38 (1st Cir. 2016).published
- United States v. Zachary Foster, 824 F.3d 84 (4th Cir. 2016).published
- United States v. James Bryant, Jr., 654 F. App'x 622 (4th Cir. 2016).unpublished
- State of Minnesota v. Henry James Johnson, No. A15-1398 (Minn. Ct. App. Aug. 1, 2016).unpublished
- United States v. Kevelin Noel, 659 F. App'x 284 (6th Cir. 2016).unpublished
- Michael Grace v. State, No. 03-15-00221-CR (Tex. App.—Austin Aug. 31, 2016).unpublished
- United States v. Tony Williams, 837 F.3d 1016 (9th Cir. 2016).published
- Clifton Crews Hoyt v. State, No. 03-14-00454-CR (Tex. App.—Austin Mar. 13, 2015).published
- Brymon Hamp, Jr. v. State of Mississippi, 207 So. 3d 684 (Miss. Ct. App. 2016).published
- Ames v. State, 153 A.3d 899 (Md. Ct. Spec. App. 2017).published
- State v. Stanage, 2017 S.D. 12, 893 N.W.2d 522.published
- Thomas Pinner v. State of Indiana, 74 N.E.3d 226 (Ind. 2017).published
- United States v. Gerald Jackson, 700 F. App'x 411 (6th Cir. 2017).unpublished
- State of Iowa v. Leon Kooima, 833 N.W.2d 202 (Iowa 2013).published
- Everett Miles v. United States, 181 A.3d 633 (D.C. 2018).published
- Ernest Foster, Sr. v. Jeremy Hellawell, 908 F.3d 1204 (9th Cir. 2018).published
- State of Washington v. Ismael M. Tarango, 434 P.3d 77 (Wash. Ct. App. 2019).published
- United States v. Anthony Miles Yarbrough, 961 F.3d 1157 (11th Cir. 2020).published
- Lamont Lendell Bagley v. Commonwealth of Virginia, 854 S.E.2d 177 (Va. Ct. App. 2021).published
- Birdie Jean Jackson v. State, No. 02-19-00370-CR (Tex. App.—Fort Worth Apr. 22, 2021).unpublished
- United States v. Gaines, No. 19-3177 (10th Cir. May 25, 2021).unpublished
- State v. Tidwell (Slip Opinion), 2021-Ohio-2072, 175 N.E.3d 527.published
- State v. King, 184 So. 3d 215 (La. Ct. App. 2015).published
- Simms v. State, 51 So. 3d 1264 (Fla. 2d DCA 2011).published
- Berry v. State, 86 So. 3d 595 (Fla. 1st DCA 2012).published
- State of Iowa v. Theodore W. Buselmeier, 974 N.W.2d 183 (Iowa Ct. App. 2021).published
- People v. Carter, 2021 IL 125954, 190 N.E.3d 224.published
- Furr v. State, 499 S.W.3d 872 (Tex. Crim. App. 2016).published
- People v. K.J. (In re K.J.), 18 Cal. App. 5th 1123 (Cal. Ct. App. 2018).published
- Commonwealth v. Costa, 862 N.E.2d 371 (Mass. 2007).published
- Commonwealth v. Mubdi, 923 N.E.2d 1004 (Mass. 2010).published
- Commonwealth v. Gomes, 937 N.E.2d 13 (Mass. 2010).published
- Commonwealth v. Anderson, 963 N.E.2d 704 (Mass. 2012).published
- In re D.W., 921 N.E.2d 1114 (Ohio Ct. App. 2d Dist. 2009).published
- State v. Jordan, 817 N.E.2d 864 (Ohio 2004).published
- United States v. Pollins, 145 F. Supp. 3d 525 (D. Md. 2015).published
- United States v. Rivas-Castro, 229 F. Supp. 3d 130 (D.P.R. 2017).published
- United States v. Browne, 233 F. Supp. 3d 814 (C.D. Cal. 2017).published
- State v. Basil, 998 A.2d 472 (N.J. 2010).published
- State v. Privott, 999 A.2d 415 (N.J. 2010).published
- State v. Edmonds, 47 A.3d 737 (N.J. 2012).published
- K.W. v. State, 906 So. 2d 383 (Fla. 2d DCA 2005).published
- Carter v. State, 651 S.E.2d 759 (Ga. Ct. App. 2007).published
- United States v. Rose, 48 F.4th 297 (5th Cir. 2022).published
- Sandor Santiago Galvante v. Commonwealth of Virginia, No. 0866211 (Va. Ct. App. Sept. 27, 2022).unpublished
- United States v. Williams, 846 F.3d 303 (9th Cir. 2016).published
- United States v. Wilhoite, 86 F. App'x 945 (6th Cir. 2004).unpublished
- United States v. Saddler, 275 F. App'x 549 (7th Cir. 2008).unpublished
- United States v. Howard, 632 F. App'x 795 (6th Cir. 2015).unpublished
- Proescher v. Bell, 966 F. Supp. 2d 1350 (N.D. Ga. 2013).published
- Parker v. Chard, 998 F. Supp. 2d 799 (D. Minn. 2014).published
- State of Maine v. Douglas E. Wilcox, 2023 ME 10, 288 A.3d 1200.published
- Adam England v. Commonwealth of Kentucky, No. 2022 CA 000849 (Ky. Ct. App. Nov. 2, 2023).unpublished
- State Of Louisiana In The Interest of K.B.J., 383 So. 3d 943 (La. Ct. App. 2024).published
- State v. Scheid, 567 P.3d 798 (Idaho Ct. App. 2025).published
- State of Missouri v. Israel Barrera, No. WD87670 (Mo. Ct. App. May 27, 2025).published
- United States v. Chavez, 660 F.3d 1215 (10th Cir. 2011).published
- Harris v. Com., 668 S.E.2d 141 (Va. 2008).published
- Jackson v. Commonwealth, 594 S.E.2d 595 (Va. 2004).published
- Daniels v. State, 628 S.E.2d 684 (Ga. Ct. App. 2006).published
- United States v. Simmons, 560 F.3d 98 (2d Cir. 2009).published
- State v. Sherry, 2004 WI App 207, 690 N.W.2d 435.published
- United States v. Williams, 608 F. Supp. 2d 325 (E.D.N.Y. 2008).published
- State v. Robinson, 2010 WI 80, 786 N.W.2d 463.published
- United States v. Hayes, 574 F. Supp. 2d 308 (W.D.N.Y. 2008).published
- United States v. Sanchez, 376 F. Supp. 2d 1264 (D.N.M. 2005).published
- United States v. Reginald Edwards, 761 F.3d 977 (9th Cir. 2014).published
- The People v. Eric R. Johnson, The People v. John A. DiSalvo, The People v. Costandino Argyris, 27 N.E.3d 425 (N.Y. 2014).published
- Com. v. McPherson, D., No. 1446 EDA 2015 (Pa. Super. Ct. Oct. 5, 2016).unpublished
- United States v. Tony Williams, No. 15-10008 (9th Cir. Jan. 11, 2017).published
- State of New Jersey Vs. James a. Bailey, No. A-4998-14T3 (N.J. Super. Ct. App. Div. May 12, 2017).unpublished
- Commonwealth v. MacKey, 177 A.3d 221 (Pa. Super. Ct. 2017).published
- In re K.J., No. A147478 (Cal. Ct. App. Jan. 3, 2018).published
- State of Tennessee v. Calvin Lyndell Dibrell, No. E2016-02279-CCA-R3-CD (Tenn. Crim. App. Mar. 26, 2018).published
- United States v. Watson, 900 F.3d 892 (7th Cir. 2018).published
- United States v. Ibrahim McCants, 911 F.3d 127 (3d Cir. 2018).published
- United States v. Ibrahim McCants, 920 F.3d 169 (3d Cir. 2019).published
- United States v. Ibrahim McCants, 952 F.3d 416 (3d Cir. 2020).published
- People v. Carter, 2019 IL App (1st) 170803 (Ill. App. Ct. 1st Dist. 2021).published
- Hadley v. State, 43 So. 3d 113 (Fla. 3d DCA 2010).published
- Commonwealth v. Famania, 946 N.E.2d 135 (Mass. App. Ct. 2011).published
- United States v. Fonville, 127 F. Supp. 3d 790 (E.D. Mich. 2015).published
- United States v. Harger, 313 F. Supp. 3d 1082 (N.D. Cal. 2018).published
- People v. Barbarich, 807 N.W.2d 56 (Mich. Ct. App. 2011).published
- State of Maine v. Timothy Barclift, 2022 ME 50, 282 A.3d 607.published
- Shuler v. State, 346 A.3d 245 (Md. Ct. Spec. App. 2025).published
- People v. Vazquez, 2026 IL App (2d) 240561-U.unpublished
- United States v. Mitchell, 233 F. App'x 547 (6th Cir. 2007).unpublished“an anonymous call reporting ‘that a young black male standing at a particular bus stop and wearing a plaid shirt was carrying a gun,’ without more, was insufficient to justify a Terry stop”
- United States v. Gomez, 623 F.3d 265 (5th Cir. 2010).published
- United States v. Aviles-Vega, 783 F.3d 69 (1st Cir. 2015).published
- United States v. Ayala, 169 F. App'x 717 (3d Cir. 2006).unpublished
At page 274 Requiring indicia of reliability for firearm tip justification84 citing casesholding that an anonymous tip must be corroborated to provide reasonable suspicion justifying an investigatory stop
- United States v. Ubiles, No. 00-3091 (3d Cir. Aug. 17, 2000). See, e.g. , Florida v. J.L., 120 S. Ct. 1375, 1379 (2000) ("The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.").
- United States v. Todd Lewis Hopkins, 268 F.3d 222 (4th Cir. 2001).published
- State v. Boyea, 765 A.2d 862 (Vt. 2000).published
- Carl Richard Cook v. Rankin Cnty., No. 2012-CT-01553-SCT (Miss. Oct. 16, 2014).published
- Carl Richard Cook v. State of Mississippi, 159 So. 3d 534 (Miss. 2015).published
- United States v. Hauk, 412 F.3d 1179 (10th Cir. 2005).published
- United States v. Dwayne Parker, 467 F. App'x 120 (3d Cir. 2012).unpublished
- United States Gov't of the Virgin Islands v. Ernie Ritter Reggy Ritter Dale Ritter, 416 F.3d 256 (3d Cir. 2005).published
- State v. Barras, 20 So. 3d 1100 (La. Ct. App. 2009).published
- State v. Crawley, 901 A.2d 924 (N.J. 2006).published
Show 64 more citing cases
- United States v. Wali, 811 F. Supp. 2d 1276 (N.D. Tex. 2011).published
- People v. Dolly, 150 P.3d 693 (Cal. 2007).published
- State v. Kevin Gamble (071234), 95 A.3d 188 (N.J. 2014).published
- United States v. Gerald Jackson, 700 F. App'x 411 (6th Cir. 2017).unpublished
- State v. King, 184 So. 3d 215 (La. Ct. App. 2015).published
- Furr v. State, 499 S.W.3d 872 (Tex. Crim. App. 2016).published
- Commonwealth v. Costa, 862 N.E.2d 371 (Mass. 2007).published
- United States v. Janvier, 798 F. Supp. 2d 362 (D. Mass. 2011).published
- State in Interest of PL, 81 So. 3d 983 (La. Ct. App. 2012).published
- K.P. v. State, 129 So. 3d 1121 (Fla. 3d DCA 2013).published
- United States v. Whitaker, 546 F.3d 902 (7th Cir. 2008).published
- M.D. ex rel. Daniels v. Smith, 504 F. Supp. 2d 1238 (M.D. Ala. 2007).published
- Commonwealth v. Gomes, 917 N.E.2d 231 (Mass. App. Ct. 2009).published
- Zachariah Ferris Houghtaling v. State, No. 10-17-00038-CR (Tex. App.—Waco Aug. 15, 2018).unpublished
- State v. Hathaway, 120 A.3d 155 (N.J. 2015).published
- United States v. Reginald Edwards, 761 F.3d 977 (9th Cir. 2014).published
- The People v. Eric R. Johnson, The People v. John A. DiSalvo, The People v. Costandino Argyris, 27 N.E.3d 425 (N.Y. 2014).published
- State of New Jersey Vs. James a. Bailey, No. A-4998-14T3 (N.J. Super. Ct. App. Div. May 12, 2017).unpublished
- Commonwealth v. MacKey, 177 A.3d 221 (Pa. Super. Ct. 2017).published
At page 276 Weighing reliability of anonymous tips and caller identification62 citing casesconc. opn. of Kennedy, J.
- People v. Allen, 950 N.E.2d 1164 (Ill. App. Ct. 4th Dist. 2011).published See, e.g., Alabama v. White, 496 U.S. 325, 331-32 (1990) (finding significant aspects of the informant’s story, especially those predicting the defendant’s future behavior, were sufficiently corroborated by the police to furnish reasonable…
- People v. Mario T., 875 N.E.2d 1241 (Ill. App. Ct. 1st Dist. 2007).published See Florida v. J.L., 529 U.S. at 271, 120 S.Ct. at 1379, 146 L.Ed.2d at 260 ("reasonableness of official suspicion must be measured by what the officers knew before they conducted their search").
- Commonwealth v. Barros, 755 N.E.2d 740 (Mass. 2001).published See Florida v. J.L., 529 U.S. 266, 271 (2000) (“reasonableness of official suspicion must be measured by what the officers knew before they conducted their search”).
- United States v. Ubiles, No. 00-3091 (3d Cir. Aug. 17, 2000). See, e.g. , Florida v. J.L., 120 S. Ct. 1375, 1379 (2000) ("The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.").
- State v. Pradubsri, 803 S.E.2d 724 (S.C. Ct. App. 2017).published “if an informant places his anonymity at risk, a court can consider this factor in weighing the reliability of the tip.”
- State v. Boyea, 765 A.2d 862 (Vt. 2000).published
- United States v. Brown, 496 F.3d 1070 (10th Cir. 2007).published
- United States v. Holmes Jr., Wendell, 360 F.3d 1339 (D.C. Cir. 2004).published
- United States v. Monteiro, 447 F.3d 39 (1st Cir. 2006).published
- People v. Rollins, 892 N.E.2d 21 (Ill. App. Ct. 4th Dist. 2008).published
Show 47 more citing cases
- Lowry v. Gutierrez, 129 Cal. App. 4th 926 (Cal. Ct. App. 2005).published
- People v. Lindsey, 148 Cal. App. 4th 1390 (Cal. Ct. App. 2007).published
- In re S.B., 44 A.3d 948 (D.C. 2012).published
- United States v. Forte, 412 F. Supp. 2d 258 (W.D.N.Y. 2006).published
- United States v. Freeman, 735 F.3d 92 (2d Cir. 2013).published
- Commonwealth v. Costa, 862 N.E.2d 371 (Mass. 2007).published
- Commonwealth v. Mubdi, 923 N.E.2d 1004 (Mass. 2010).published
- State v. Napoleao Pires, 316 A.3d 701 (R.I. 2024).published
- United States v. Aviles-Vega, 783 F.3d 69 (1st Cir. 2015).published“The mere fact that a tip, if true, would describe illegal activity does not mean that the police may make a Terry stop without meeting the reliability requirement. ...”
- United States v. Ayala, 169 F. App'x 717 (3d Cir. 2006).unpublished
At page 273 Assessing reliability of anonymous tips for searches49 citing cases“Several Courts of Appeals have held it per se foreseeable for people carrying significant amounts of illegal drugs to be carrying guns as well.”
- State v. Hopkins, 117 P.3d 377 (Wash. Ct. App. 2005).published See, e.g., J.L, 529 U.S. at 271 (“The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.
- United States v. Robinson, No. 00-1328 (3d Cir. Sept. 13, 2002).published Florida v. J.L., 529 U.S. 266, 271 (2000) ("The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.").
- Carl Richard Cook v. Rankin Cnty., No. 2012-CT-01553-SCT (Miss. Oct. 16, 2014).published
- Carl Richard Cook v. State of Mississippi, 159 So. 3d 534 (Miss. 2015).published
- United States v. Monteiro, 447 F.3d 39 (1st Cir. 2006).published
- United States v. James Edward Elston, Jr., 479 F.3d 314 (4th Cir. 2007).published
- United States v. Crandell, 509 F. Supp. 2d 435 (D.N.J. 2007).published
- State v. Barras, 20 So. 3d 1100 (La. Ct. App. 2009).published
- Garcia v. Commonwealth, 335 S.W.3d 444 (Ky. Ct. App. 2010).published
- Johnson v. Williams, 584 F. Supp. 2d 97 (D.D.C. 2008).published
Show 37 more citing cases
- People v. Dolly, 150 P.3d 693 (Cal. 2007).published
- United States v. Andre Williams, 731 F.3d 678 (7th Cir. 2013).published
- State of Iowa v. Leon Kooima, 833 N.W.2d 202 (Iowa 2013).published
- Furr v. State, 499 S.W.3d 872 (Tex. Crim. App. 2016).published
- Commonwealth v. Gomes, 937 N.E.2d 13 (Mass. 2010).published
- State v. Urioste, 2002-NMSC-023, 52 P.3d 964.published
- In re A.J. M.-b, 713 S.E.2d 104 (N.C. Ct. App. 2011).published
- State of Tennessee v. Jerry Lee Hanning, 296 S.W.3d 44 (Tenn. 2009).published
- Leroy Duffie v. City of Lincoln, 834 F.3d 877 (8th Cir. 2016).published
- Commonwealth v. MacKey, 177 A.3d 221 (Pa. Super. Ct. 2017).published
At page 269 Reliability of anonymous tips for reasonable suspicion49 citing cases“[a]nonymous tips . . . are generally less reliable than tips from known informants and can form the basis for reasonable suspicion only if accompanied by specific indicia of reliability”
- State v. Frazier, 542 S.E.2d 682 (N.C. Ct. App. 2001).published “[a]nonymous tips . . . are generally less reliable than tips from known informants and can form the basis for reasonable suspicion only if accompanied by specific indicia of reliability”
- United States v. Todd Lewis Hopkins, 268 F.3d 222 (4th Cir. 2001).published
- United States v. Monteiro, 447 F.3d 39 (1st Cir. 2006).published
- United States v. Crandell, 509 F. Supp. 2d 435 (D.N.J. 2007).published
- State v. Barras, 20 So. 3d 1100 (La. Ct. App. 2009).published
- Baptiste v. State, 995 So. 2d 285 (Fla. 2008).published
- Martinez v. State, 318 S.W.3d 24 (Tex. App.—San Antonio 2010).published
- State of Iowa v. Leon Kooima, 833 N.W.2d 202 (Iowa 2013).published
- State v. King, 184 So. 3d 215 (La. Ct. App. 2015).published
- United States v. Benavides, 291 F. App'x 603 (5th Cir. 2008).unpublished
Show 32 more citing cases
- United States v. Clipper, Ronald, 313 F.3d 605 (D.C. Cir. 2002).published
- Murphy v. Commonwealth, 570 S.E.2d 836 (Va. 2002).published
- Craig M. Lantion v. Commonwealth of Virginia, No. 2617054 (Va. Ct. App. Dec. 18, 2007).unpublished
- Jason Andre Williams v. Commonwealth, No. 0783041 (Va. Ct. App. Mar. 29, 2005).unpublished
- State v. Urioste, 2002-NMSC-023, 52 P.3d 964.published
- William M. Smith, Jr. v. State, No. 12-07-00214-CR (Tex. App.—Tyler Sept. 3, 2008).published
- State of Maine v. Timothy Barclift, 2022 ME 50, 282 A.3d 607.published
At page 275 Assessing reliability of anonymous telephone tips40 citing casesconc, opn. of Kennedy, J.
- State v. Hopkins, 117 P.3d 377 (Wash. Ct. App. 2005).published See, e.g., J.L, 529 U.S. at 271 (“The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.
- United States v. Brown, No. 04-4353 (4th Cir. Mar. 25, 2005).published See J.L., 529 U.S. at 271 ("The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search."). "[A]n officer may, consistent with the Fourth Amendment, conduct a brief, investigatory…
- State v. Boyea, 765 A.2d 862 (Vt. 2000).published
- United States v. Brown, 496 F.3d 1070 (10th Cir. 2007).published
- People v. Jordan, 121 Cal. App. 4th 544 (Cal. Ct. App. 2004).published
- In re S.B., 44 A.3d 948 (D.C. 2012).published
- United States v. Freeman, 735 F.3d 92 (2d Cir. 2013).published
- People v. Lomax, 2012 IL App (1st) 103016, 975 N.E.2d 115.published
- State v. Urioste, 2002-NMSC-023, 52 P.3d 964.published
- United States v. Monya Townsend, 472 F. App'x 625 (9th Cir. 2012).unpublished
Show 28 more citing cases
- Conway Spence Hyman v. Commonwealth of Virginia, No. 0519181 (Va. Ct. App. Oct. 22, 2019).unpublished
- United States v. Everett Oshae Brown, 401 F.3d 588 (4th Cir. 2005).published
- Commonwealth v. Wiley, 858 A.2d 1191 (Pa. Super. Ct. 2004).published
- Martinez, John David, No. PD-1238-10 (Tex. Crim. App. June 29, 2011).published
- Commonwealth v. Gomes, 917 N.E.2d 231 (Mass. App. Ct. 2009).published
- Jackson v. Commonwealth, 594 S.E.2d 595 (Va. 2004).published
146 L. Ed. 2d at 268 Determining sufficiency of anonymous tip for stop and frisk11 citing cases
- United States v. Holmes Jr., Wendell, 360 F.3d 1339 (D.C. Cir. 2004).published
- State v. Basil, 998 A.2d 472 (N.J. 2010).published
- United States v. Howard, 632 F. App'x 795 (6th Cir. 2015).unpublished
- State of Missouri v. Israel Barrera, No. WD87670 (Mo. Ct. App. May 27, 2025).published
- United States v. Jorges Valdes, 403 F. App'x 885 (5th Cir. 2010).unpublished
- United States v. Wade Allen Wheat, 278 F.3d 722 (8th Cir. 2001).published
- United States v. Hampton, 585 F.3d 1033 (7th Cir. 2009).published
- Bloomingdale v. State, 842 A.2d 1212 (Del. 2004).published
- United States v. Mack, 145 F. Supp. 3d 635 (M.D. La. 2015).published
- Daniels v. State, 628 S.E.2d 684 (Ga. Ct. App. 2006).published
Show 1 more citing case
- United States v. Simmons, 560 F.3d 98 (2d Cir. 2009).published
At page 266 Determining probable cause from anonymous tips and descriptions7 citing casesApart from the tip, the officers had no reason to suspect any of the three of illegal conduct
- Com. v. Vazquez, J., No. 3618 EDA 2017 (Pa. Super. Ct. Oct. 5, 2018).unpublished(Apart from the tip, the officers had no reason to suspect any of the three of illegal conduct)
- United States v. Mitchell, 388 F. App'x 328 (4th Cir. 2010).unpublished
- United States v. Todd Lewis Hopkins, 268 F.3d 222 (4th Cir. 2001).published
- Commonwealth v. Brown, 250 S.W.3d 631 (Ky. 2008).published
- United States v. Avagyan, 164 F. Supp. 3d 864 (E.D. Va. 2016).published
- Commonwealth v. Bernard, 28 Mass. L. Rptr. 562 (Mass. Super. Ct. 2011).published
146 L. Ed. 2d at 271 Assessing reliability of anonymous tips for stop and frisk4 citing cases
- In re D.W., 921 N.E.2d 1114 (Ohio Ct. App. 2d Dist. 2009).published
- State v. Basil, 998 A.2d 472 (N.J. 2010).published
- Flonnory v. State, 805 A.2d 854 (Del. 2001).published
- State v. Haynesworth, 2019-Ohio-1986.published
At page 267 Identifying counsel and parties in the case4 citing casesGinsburg, J., delivered the opinion for a unanimous Court. Kennedy, J., filed a concurring opinion, in which Rehnquist, C. J., joined, post, p. 274. Michael J.…
- United States v. William Colon, 250 F.3d 130 (2d Cir. 2001).published
- State v. Boyea, 765 A.2d 862 (Vt. 2000).published
- Carl Richard Cook v. Rankin Cnty., No. 2012-CT-01553-SCT (Miss. Oct. 16, 2014).published
- Carl Richard Cook v. State of Mississippi, 159 So. 3d 534 (Miss. 2015).published
The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.
- People of Michigan v. Delon Martease Bouler, No. 379121 (Mich. Ct. App. Sept. 22, 2026).unpublished (The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
- Sanchez, Reinaldo, 538 S.W.3d 545 (Tex. Crim. App. 2017).published(The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search.)
At page 353 tip from an identified informant or concerned citizen coupled with some corroborative police investigation is sufficient to create reasonable suspicion for an investigative stop1 citing case
- State v. Renzulli, 935 N.E.2d 200 (Ind. Ct. App. 2010).published (tip from an identified informant or concerned citizen coupled with some corroborative police investigation is sufficient to create reasonable suspicion for an investigative stop)
Other citing cases
- United States v. Romal Hunter, 333 F. App'x 920 (6th Cir. 2009).unpublished
- Karadi v. Jenkins, 7 F. App'x 185 (4th Cir. 2001).unpublished
- United States v. Mills, 372 F. Supp. 3d 517 (E.D. Mich. 2019).published
v.
J. L.
[*267] Ginsburg, J., delivered the opinion for a unanimous Court. Kennedy, J., filed a concurring opinion, in which Rehnquist, C. J., joined, post, p. 274.
Michael J. Neimand, Assistant Attorney General of Florida, argued the cause for petitioner. With him on the briefs was Robert A. Butterworth, Attorney General.
Irving L. Gornstein argued the cause for the United States as amicus curiae urging reversal. With him on the brief were Solicitor General Waxman, Assistant Attorney General Robinson, and Deputy Solicitor General Dreeben.
Harvey J. Sepler argued the cause for respondent. With him on the brief were Bennett H. Brummer and Andrew Stanton.[*]
[*268] Justice Ginsburg, delivered the opinion of the Court.
The question presented in this case is whether an anonymous tip that a person is carrying a gun is, without more, sufficient to justify a police officer's stop and frisk of that person. We hold that it is not.
I
On October 13, 1995, an anonymous caller reported to the Miami-Dade Police that a young black male standing at a particular bus stop and wearing a plaid shirt was carrying a gun. App. to Pet. for Cert. A-40 to A-41. So far as the record reveals, there is no audio recording of the tip, and nothing is known about the informant. Sometime after the police received the tip—the record does not say how long— two officers were instructed to respond. They arrived at the bus stop about six minutes later and saw three black males "just hanging out [there]." Id., at A-42. One of the three, respondent J. L., was wearing a plaid shirt. Id., at A-41. Apart from the tip, the officers had no reason to suspect any of the three of illegal conduct. The officers did not see a firearm, and J. L. made no threatening or otherwise unusual movements. Id., at A-42 to A-44. One of the officers approached J. L., told him to put his hands up on the bus stop, frisked him, and seized a gun from J. L.'s pocket. The second officer frisked the other two individuals, against whom no allegations had been made, and found nothing.
[*269] J. L., who was at the time of the frisk "10 days shy of his 16th birth[day]," Tr. of Oral Arg. 6, was charged under state law with carrying a concealed firearm without a license and possessing a firearm while under the age of 18. He moved to suppress the gun as the fruit of an unlawful search, and the trial court granted his motion. The intermediate appellate court reversed, but the Supreme Court of Florida quashed that decision and held the search invalid under the Fourth Amendment. 727 So. 2d 204 (1998).
Anonymous tips, the Florida Supreme Court stated, are generally less reliable than tips from known informants and can form the basis for reasonable suspicion only if accompanied by specific indicia of reliability, for example, the correct forecast of a subject's "`not easily predicted' " movements. Id., at 207 (quoting Alabama v. White, 496 U. S. 325, 332 (1990)). The tip leading to the frisk of J. L., the court observed, provided no such predictions, nor did it contain any other qualifying indicia of reliability. 727 So. 2d, at 207-208. Two justices dissented. The safety of the police and the public, they maintained, justifies a "firearm exception" to the general rule barring investigatory stops and frisks on the basis of bare-boned anonymous tips. Id., at 214-215.
Seeking review in this Court, the State of Florida noted that the decision of the State's Supreme Court conflicts with decisions of other courts declaring similar searches compatible with the Fourth Amendment. See, e. g., United States v. DeBerry, 76 F. 3d 884, 886-887 (CA7 1996); United States v. Clipper, 973 F. 2d 944, 951 (CADC 1992). We granted certiorari, 528 U. S. 963 (1999), and now affirm the judgment of the Florida Supreme Court.
II
Our "stop and frisk" decisions begin with Terry v. Ohio, 392 U. S. 1 (1968). This Court held in Terry:
"[W]here a police officer observes unusual conduct which leads him reasonably to conclude in light of his[*270] experience that criminal activity may be afoot and that the persons with whom he is dealing may be armed and presently dangerous, where in the course of investigating this behavior he identifies himself as a policeman and makes reasonable inquiries, and where nothing in the initial stages of the encounter serves to dispel his reasonable fear for his own or others' safety, he is entitled for the protection of himself and others in the area to conduct a carefully limited search of the outer clothing of such persons in an attempt to discover weapons which might be used to assault him." Id., at 30.
In the instant case, the officers' suspicion that J. L. was carrying a weapon arose not from any observations of their own but solely from a call made from an unknown location by an unknown caller. Unlike a tip from a known informant whose reputation can be assessed and who can be held responsible if her allegations turn out to be fabricated, see Adams v. Williams, 407 U. S. 143, 146-147 (1972), "an anonymous tip alone seldom demonstrates the informant's basis of knowledge or veracity," Alabama v. White, 496 U. S., at 329. As we have recognized, however, there are situations in which an anonymous tip, suitably corroborated, exhibits "sufficient indicia of reliability to provide reasonable suspicion to make the investigatory stop." Id., at 327. The question we here confront is whether the tip pointing to J. L. had those indicia of reliability.
In White, the police received an anonymous tip asserting that a woman was carrying cocaine and predicting that she would leave an apartment building at a specified time, get into a car matching a particular description, and drive to a named motel. Ibid. Standing alone, the tip would not have justified a Terry stop. 496 U. S., at 329. Only after police observation showed that the informant had accurately predicted the woman's movements, we explained, did it become reasonable to think the tipster had inside knowledge about the suspect and therefore to credit his assertion about the cocaine.[*271] Id., at 332. Although the Court held that the suspicion in White became reasonable after police surveillance, we regarded the case as borderline. Knowledge about a person's future movements indicates some familiarity with that person's affairs, but having such knowledge does not necessarily imply that the informant knows, in particular, whether that person is carrying hidden contraband. We accordingly classified White as a "close case." Ibid.
The tip in the instant case lacked the moderate indicia of reliability present in White and essential to the Court's decision in that case. The anonymous call concerning J. L. provided no predictive information and therefore left the police without means to test the informant's knowledge or credibility. That the allegation about the gun turned out to be correct does not suggest that the officers, prior to the frisks, had a reasonable basis for suspecting J. L. of engaging in unlawful conduct: The reasonableness of official suspicion must be measured by what the officers knew before they conducted their search. All the police had to go on in this case was the bare report of an unknown, unaccountable informant who neither explained how he knew about the gun nor supplied any basis for believing he had inside information about J. L. If White was a close case on the reliability of anonymous tips, this one surely falls on the other side of the line.
Florida contends that the tip was reliable because its description of the suspect's visible attributes proved accurate: There really was a young black male wearing a plaid shirt at the bus stop. Brief for Petitioner 20-21. The United States as amicus curiae makes a similar argument, proposing that a stop and frisk should be permitted "when (1) an anonymous tip provides a description of a particular person at a particular location illegally carrying a concealed firearm, (2) police promptly verify the pertinent details of the tip except the existence of the firearm, and (3) there are no factors that cast doubt on the reliability of the tip . . . ." Brief[*272] for United States 16. These contentions misapprehend the reliability needed for a tip to justify a Terry stop.
An accurate description of a subject's readily observable location and appearance is of course reliable in this limited sense: It will help the police correctly identify the person whom the tipster means to accuse. Such a tip, however, does not show that the tipster has knowledge of concealed criminal activity. The reasonable suspicion here at issue requires that a tip be reliable in its assertion of illegality, not just in its tendency to identify a determinate person. Cf. 4 W. LaFave, Search and Seizure § 9.4(h), p. 213 (3d ed. 1996) (distinguishing reliability as to identification, which is often important in other criminal law contexts, from reliability as to the likelihood of criminal activity, which is central in anonymous-tip cases).
A second major argument advanced by Florida and the United States as amicus is, in essence, that the standard Terry analysis should be modified to license a "firearm exception." Under such an exception, a tip alleging an illegal gun would justify a stop and frisk even if the accusation would fail standard pre-search reliability testing. We decline to adopt this position.
Firearms are dangerous, and extraordinary dangers sometimes justify unusual precautions. Our decisions recognize the serious threat that armed criminals pose to public safety; Terry `s rule, which permits protective police searches on the basis of reasonable suspicion rather than demanding that officers meet the higher standard of probable cause, responds to this very concern. See 392 U. S., at 30. But an automatic firearm exception to our established reliability analysis would rove too far. Such an exception would enable any person seeking to harass another to set in motion an intrusive, embarrassing police search of the targeted person simply by placing an anonymous call falsely reporting the target's unlawful carriage of a gun. Nor could one securely confine such an exception to allegations involving firearms.[*273] Several Courts of Appeals have held it per se foreseeable for people carrying significant amounts of illegal drugs to be carrying guns as well. See, e. g., United States v. Sakyi, 160 F. 3d 164, 169 (CA4 1998); United States v. Dean, 59 F. 3d 1479, 1490, n. 20 (CA5 1995); United States v. Odom, 13 F. 3d 949, 959 (CA6 1994); United States v. Martinez, 958 F. 2d 217, 219 (CA8 1992). If police officers may properly conduct Terry frisks on the basis of bare-boned tips about guns, it would be reasonable to maintain under the above-cited decisions that the police should similarly have discretion to frisk based on bare-boned tips about narcotics. As we clarified when we made indicia of reliability critical in Adams and White, the Fourth Amendment is not so easily satisfied. Cf. Richards v. Wisconsin, 520 U. S. 385, 393-394 (1997) (rejecting a per se exception to the "knock and announce" rule for narcotics cases partly because "the reasons for creating an exception in one category [of Fourth Amendment cases] can, relatively easily, be applied to others," thus allowing the exception to swallow the rule).[*]
The facts of this case do not require us to speculate about the circumstances under which the danger alleged in an anonymous tip might be so great as to justify a search even without a showing of reliability. We do not say, for example, that a report of a person carrying a bomb need bear the[*274] indicia of reliability we demand for a report of a person carrying a firearm before the police can constitutionally conduct a frisk. Nor do we hold that public safety officials in quarters where the reasonable expectation of Fourth Amendment privacy is diminished, such as airports, see Florida v. Rodriguez, 469 U. S. 1 (1984) (per curiam), and schools, see New Jersey v. T. L. O., 469 U. S. 325 (1985), cannot conduct protective searches on the basis of information insufficient to justify searches elsewhere.
Finally, the requirement that an anonymous tip bear standard indicia of reliability in order to justify a stop in no way diminishes a police officer's prerogative, in accord with Terry, to conduct a protective search of a person who has already been legitimately stopped. We speak in today's decision only of cases in which the officer's authority to make the initial stop is at issue. In that context, we hold that an anonymous tip lacking indicia of reliability of the kind contemplated in Adams and White does not justify a stop and frisk whenever and however it alleges the illegal possession of a firearm.
The judgment of the Florida Supreme Court is affirmed.
It is so ordered.
Justice Kennedy, with whom The Chief Justice joins, concurring.
On the record created at the suppression hearing, the Court's decision is correct. The Court says all that is necessary to resolve this case, and I join the opinion in all respects. It might be noted, however, that there are many indicia of reliability respecting anonymous tips that we have yet to explore in our cases.
When a police officer testifies that a suspect aroused the officer's suspicion, and so justifies a stop and frisk, the courts can weigh the officer's credibility and admit evidence seized pursuant to the frisk even if no one, aside from the officer and defendant themselves, was present or observed the seizure.[*275] An anonymous telephone tip without more is different, however; for even if the officer's testimony about receipt of the tip is found credible, there is a second layer of inquiry respecting the reliability of the informant that cannot be pursued. If the telephone call is truly anonymous, the informant has not placed his credibility at risk and can lie with impunity. The reviewing court cannot judge the credibility of the informant and the risk of fabrication becomes unacceptable.
On this record, then, the Court is correct in holding that the telephone tip did not justify the arresting officer's immediate stop and frisk of respondent. There was testimony that an anonymous tip came in by a telephone call and nothing more. The record does not show whether some notation or other documentation of the call was made either by a voice recording or tracing the call to a telephone number. The prosecution recounted just the tip itself and the later verification of the presence of the three young men in the circumstances the Court describes.
It seems appropriate to observe that a tip might be anonymous in some sense yet have certain other features, either supporting reliability or narrowing the likely class of informants, so that the tip does provide the lawful basis for some police action. One such feature, as the Court recognizes, is that the tip predicts future conduct of the alleged criminal. There may be others. For example, if an unnamed caller with a voice which sounds the same each time tells police on two successive nights about criminal activity which in fact occurs each night, a similar call on the third night ought not be treated automatically like the tip in the case now before us. In the instance supposed, there would be a plausible argument that experience cures some of the uncertainty surrounding the anonymity, justifying a proportionate police response. In today's case, however, the State provides us with no data about the reliability of anonymous tips. Nor do we know whether the dispatcher or arresting officer had any[*276] objective reason to believe that this tip had some particular indicia of reliability.
If an informant places his anonymity at risk, a court can consider this factor in weighing the reliability of the tip. An instance where a tip might be considered anonymous but nevertheless sufficiently reliable to justify a proportionate police response may be when an unnamed person driving a car the police officer later describes stops for a moment and, face to face, informs the police that criminal activity is occurring. This too seems to be different from the tip in the present case. See United States v. Sierra-Hernandez, 581 F. 2d 760 (CA9 1978).
Instant caller identification is widely available to police, and, if anonymous tips are proving unreliable and distracting to police, squad cars can be sent within seconds to the location of the telephone used by the informant. Voice recording of telephone tips might, in appropriate cases, be used by police to locate the caller. It is unlawful to make false reports to the police, e. g., Fla. Stat. Ann. § 365.171(16) (Supp. 2000); Fla. Stat. § 817.49 (1994), and the ability of the police to trace the identity of anonymous telephone informants may be a factor which lends reliability to what, years earlier, might have been considered unreliable anonymous tips.
These matters, of course, must await discussion in other cases, where the issues are presented by the record.
[*] Briefs of amici curiae urging reversal were filed for Americans for Effective Law Enforcement, Inc., et al. by Wayne W. Schmidt, James P. Manak, Richard Weintraub, and Bernard J. Farber; for the Justice Coalition by Scott D. Makar; for the National Association of Police Organizations by Stephen R. McSpadden; and for the State of Illinois et al. by James E. Ryan, Attorney General of Illinois, Joel D. Bertocchi, Solicitor General, William Browers and Michael M. Glick, Assistant Attorneys General, and Dan Schweitzer, joined by the Attorneys General for their respective jurisdictions as follows: Bill Pryor of Alabama, Janet Napolitano of Arizona, Mark Pryor of Arkansas, Bill Lockyer of California, Ken Salazar of Colorado, John M. Bailey of Connecticut, M. Jane Brady of Delaware, Earl I. Anzai of Hawaii, Jeffrey A. Modisett of Indiana, Thomas J. Miller of Iowa, Carla J. Stovall of Kansas, Richard P. Ieyoub of Louisiana, J. Joseph Curran of Maryland, Jennifer M. Granholm of Michigan, Mike Hatch of Minnesota, Jeremiah W. (Jay) Nixon of Missouri, Joseph P. Mazurek of Montana, Frankie Sue Del Papa of Nevada, Philip T. McLaughlin of New Hampshire, Patricia A. Madrid of New Mexico, Michael F. Easley of North Carolina, Betty D. Montgomery of Ohio, W. A. Drew Edmondson of Oklahoma, Hardy Myers of Oregon, D. Michael Fisher of Pennsylvania, Jose A. Fuentes Agostini of Puerto Rico, Sheldon Whitehouse of Rhode Island, Charles M. Condon of South Carolina, Paul G. Summers of Tennessee, John Cornyn of Texas, Jan Graham of Utah, Christine O. Gregoire of Washington, and Gay Woodhouse of Wyoming.
Briefs of amici curiae urging affirmance were filed for the Congress of Racial Equality, Inc., by Stefan B. Tahmassebi; for the National Association of Criminal Defense Lawyers et al. by James J. Tomkovicz and Barbara E. Bergman; for the National Rifle Association of America et al. by Robert Dowlut and David B. Kopel; and for the Rutherford Institute by John W. Whitehead and Steven H. Aden.
[*] At oral argument, petitioner also advanced the position that J.L.'s youth made the stop and frisk valid, because it is a crime in Florida for persons under the age of 21 to carry concealed firearms. See Fla. Stat. § 790.01 (1997) (carrying a concealed weapon without a license is a misdemeanor), § 790.06(2)(b) (only persons aged 21 or older may be licensed to carry concealed weapons). This contention misses the mark. Even assuming that the arresting officers could be sure that J.L. was under 21, they would have had reasonable suspicion that J. L. was engaged in criminal activity only if they could be confident that he was carrying a gun in the first place. The mere fact that a tip, if true, would describe illegal activity does not mean that the police may make a Terry stop without meeting the reliability requirement, and the fact that J. L. was under 21 in no way made the gun tip more reliable than if he had been an adult.