- Does the Fourth Amendment require that an officer who receives an anonymous tip about a drunken or reckless driver corroborate dangerous driving before stopping the vehicle?
- Does an anonymous, uncorroborated tip that a vehicle ran someone off the road create reasonable suspicion to stop the vehicle?
In August 2008, a Mendocino County 911 dispatcher received a call from another county dispatcher reporting that a silver Ford truck had run another car off the road. The car occupants had anonymously reported that the truck ran them off the road. A police officer saw the truck, pulled it over, searched it, and found four large bags of marijuana, and arrested Jose and Lorenzo Navarette for marijuana transportation, possession, and sale. The Navarettes filed a motion to suppress evidence of the marijuana, arguing that the anonymous tip was not sufficient to justify the stop because the officer did not independently corroborate the alleged illegal activity. The magistrate judge denied the motion to suppress, and on appeal, the California Court of Appeal held that the officer had reasonable suspicion to stop the vehicle. The Supreme Court granted certiorari to decide whether an anonymous tip must be corroborated in order to create a reasonable suspicion of criminal activity. This case will impact the continuing development of Fourth Amendment law. The Navarettes argue that the Fourth Amendment requires independent corroboration of reckless driving in order for an anonymous tip to justify stopping a vehicle. California responds that because of the state’s interest in protecting the public, an anonymous tip can supply reasonable suspicion absent police corroboration.
- Does the Fourth Amendment require an officer who receives an anonymous tip regarding a drunken or reckless driver to corroborate dangerous driving before stopping the vehicle?
- Does an anonymous tip that a specific vehicle ran someone off the road provide reasonable suspicion to stop a vehicle, where the detaining officer was only advised to be on the lookout for a reckless driver, and the officer could not corroborate dangerous driving despite following the suspect vehicle for several miles?
On August 23, 2008, Mendocino County 911 dispatchers received a call from the Humboldt County dispatcher reporting that a silver Ford F150 pickup truck with an identified license-plate number had run another car off the road at mile marker 88 on southbound Highway 1. See People v. Navarette, 2012 Cal. App. Unpub. at 2–3, 2012 BL 268067 (Oct.
- Sherry Colb, The U.S. Supreme Court Considers Anonymous Tips: Part Two, Justia.com (Oct. 23, 2013)
- Lawrence Hurley,U.S. Justices agree to hear traffic stop case, Reuters (Oct. 1, 2013)