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Navarette v. California


A police dispatcher received an anonymous call from a woman stating a silver Ford pickup truck had just run the woman’s vehicle off the roadway. The woman provided the pickup truck’s license plate number, approximate location and direction of travel. The dispatcher broadcast the woman’s information and a few minutes later police officers saw a silver Ford pickup truck with the same license plate number, near the location and traveling in the same direction reported by the woman. The officer conducted a traffic stop, and as he and a back-up officer approached the pickup truck, the officers smelled the odor of marijuana. The officers searched the pickup truck, found four large bags of marijuana and arrested the driver, Navarette, and his brother, who was a passenger.

Navarette moved to suppress the marijuana, arguing the anonymous 911 call did not
provide the officers reasonable suspicion to conduct the traffic stop.


Whether the Fourth Amendment requires an officer who receives an anonymous tip regarding a drunken or reckless driver to corroborate dangerous driving before stopping the vehicle


No. In this case, the traffic stop did not violate the Fourth Amendment because, under the totality of the circumstances, the officer had reasonable suspicion that the driver of the truck was intoxicated.


The court held the 911 call was sufficiently reliable to credit the woman’s claim that Navarette’s truck had run her vehicle off the road. First, the woman described the truck, provided its license plate information and gave the truck’s location to the 911 dispatcher. Second, the police officer located the truck approximately 19 miles away from the scene of the incident, approximately 18 minutes after the 911 call. Third, the woman’s use of the 911 system was a factor to take into account when determining the reliability of the information she provided. The 911 system had features that allowed for identifying and tracing callers, which would allow a reasonable officer to believe that a person might think twice before calling in a false report. Consequently, the woman’s detailed, firsthand description of Navarette’s truck and dangerous driving along with the timeline of events suggested the woman called 911 shortly after she was run off the road, which entitled her tip to be considered reliable by the police officer.

Next, the court recognized a reliable tip will justify an investigative stop only if the tip creates a reasonable suspicion that “criminal activity may be afoot.” In this case, the court held the woman’s report of being run off the roadway created reasonable suspicion of an ongoing crime such as drunk driving. The court stated that running another vehicle off the road suggests lane-positioning problems, decreased vigilance, impaired judgment, or some combination of recognized drunk-driving cues. Because the 911 call established reasonable suspicion to stop Navarette, the officer did not need to follow Navarette to personally observe suspicious driving before conducting the traffic stop.


572 U.S. ___, 134 S. Ct. 1683 (2014)

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