The “Anonymous-Tip-Plus-Very-Little-Else” Rule

The “Anonymous-Tip-Plus-Very-Little-Else” Rule

Robert C. Phillips
Deputy District Attorney (Ret.)
June, 2014

The United States Supreme Court determined over a decade ago in Florida v. J.L. that an uncorroborated anonymous tip is legally insufficient to justify a detention and a patdown for weapons.  The problem with this rule is that it makes it unnecessarily dangerous for an officer to approach a potentially armed suspect when based on nothing more than an anonymous tip.

Contacting a potentially deadly suspect without the legal power to protect oneself is not a position in which any law enforcement officer likes to find him or herself.  California courts, believe it or not, have been uncomfortable with this as well.  The courts, therefore, have been looking for exceptions.  The United States Supreme Court has finally followed California’s lead and instituted a new rule that we might appropriately entitle the “anonymous-tip-plus-very-little-else” rule.

In Navarette v. California (Apr. 22, 2014)134 S. Ct. 1683, the High Court held, although in a context wholly different than in J.L., that an anonymous tip concerning a driver of a specifically described vehicle committing a single act of recklessness “might” be enough to provide a police officer with the necessary reasonable suspicion to believe that the driver was driving while intoxicated, thus justifying a traffic stop and detention of the driver. 

In Navarette, a woman called the California Highway Patrol 911 emergency number and reported that she had just been run off the road by the driver of a silver Ford 150 pickup with a license plate number of 8D94925.  She told the dispatcher that the incident happened on southbound highway 1, at mile marker 88, in Humboldt County.  This information was passed along to CHP officers in neighboring Mendocino County. 

A northbound CHP officer passed the suspect vehicle at mile marker 69, 18 minutes after the incident, about 19 miles away.  The officer did a ....

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