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Officers received an anonymous telephone tip that the defendant would be leaving an apartment complex at a certain time, driving a brown Plymouth station wagon with a broken right taillight lens. The anonymous source stated the defendant would drive to a specific motel and would be in possession of approximately one ounce of cocaine in a brown attaché case. The officers did not know if the anonymous caller was reliable or how the caller knew this information. The officers went to the apartment complex and located a Plymouth station wagon with a broken right taillight in the parking lot. The officers observed the defendant leave the building and enter the station wagon. The officers followed her as she drove to the motel identified by the anonymous source. The officers stopped her. After obtaining the defendant’s consent to search the vehicle, the officers found a locked brown attaché case. The defendant provided the combination to the case and upon opening it the officers found marijuana. The defendant was arrested. During processing, the officers found cocaine in her purse.
Whether the corroborated anonymous tip was sufficiently reliable so as to give the officers reasonable suspicion for the stop of the defendant?
Yes. The corroboration of the anonymous tip by independent police work furnished reasonable suspicion for the stop.
The Court held that “the totality of the circumstances” approach for determining probable cause is also relevant for determining reasonable suspicion. While the tip provided in this case does not, by itself, give rise to reasonable suspicion, the corroboration of significant aspects of the tip by independent investigation provided the indicia of reliability. The Court found it to be critical that the tipster was able to predict the defendant’s future behavior. This showed the tipster possessed “inside information – a special familiarity with the defendant’s affairs” that most members of the general public would not have. The corroboration of much of the tipster’s information gave reason to believe that he was “honest” and “well informed.” Based on these facts, “it is not unreasonable to conclude in this case that the independent corroboration by the police of significant aspects of the informer’s predictions imparted some degree of reliability to the other allegations made by the caller.”
496 U.S. 325, 110 S. Ct. 2412 (1990)
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