## Facts

- Police received an anonymous 911 call reporting a “suspicious” Black male wearing a blue coat in front of a specified address, without describing criminal conduct.
- Officers responded at night to the location and observed Joseph Jones, who matched the clothing description, standing nearby and not engaging in suspicious activity.
- An officer ordered Jones to stop and remove his hands from his pockets; Jones did not comply and began walking away.
- A physical confrontation followed, during which Jones discarded an object later determined to contain cocaine; additional contraband was recovered from his person and the area.
- Jones was charged with drug offenses and resisting arrest and moved to suppress the evidence as the product of an unconstitutional seizure.
- The trial court denied suppression and convicted Jones on a stipulated record; Jones appealed.

## Issues

1. Whether an anonymous tip describing a “suspicious” person, combined with presence in a high-crime area at night, provided reasonable and articulable suspicion to justify a seizure under the Delaware Constitution.
2. Whether the officer’s command to stop and remove hands from pockets constituted a “seizure” requiring reasonable suspicion.
3. Whether contraband recovered after the confrontation was admissible if the initial seizure was unlawful.

## Decision

- The Delaware Supreme Court reversed the denial of the motion to suppress and vacated the conviction.
- The court held the officers lacked reasonable, articulable suspicion because the anonymous tip lacked indicia of reliability and did not describe specific criminal activity.
- The court held that presence in a high-crime area at night did not, without more, justify a stop.
- The court concluded that the officer’s directive to stop and remove hands from pockets constituted a seizure under Delaware law, triggering the reasonable-suspicion requirement.
- The court held the recovered drugs and related evidence were inadmissible as fruit of the unlawful seizure.

## Legal Principles

- An anonymous tip that merely labels a person “suspicious,” without particularized information indicating criminal activity and reliability, is insufficient to establish reasonable, articulable suspicion.
- Presence in a high-crime area, even at night, does not by itself create reasonable suspicion for a stop.
- Under the Delaware Constitution, a police show of authority that restrains liberty—such as ordering a person to stop and comply with commands—can constitute a seizure requiring reasonable suspicion.
- Evidence obtained as a result of an unlawful seizure must be suppressed, and later-discovered contraband cannot retroactively justify the initial stop.

## Conclusion

The Delaware Supreme Court held that officers unconstitutionally seized Jones based solely on an unreliable anonymous report and his presence in a high-crime area, requiring suppression of the drug evidence and reversal of his conviction.


Jones v. State, 745 A.2d 856 (Del. 1999)