Facts
- A 911 dispatcher received a report that a silver Ford F-150 pickup truck, identified by license plate, had run the caller’s car off the road on southbound Highway 1 near a specified mile marker.
- California Highway Patrol officers located a truck matching the description and followed it briefly without observing erratic or illegal driving.
- An officer stopped the truck based on the 911 report.
- As officers approached, they smelled marijuana and searched the vehicle, finding about 30 pounds of marijuana in the truck bed.
- Lorenzo Prado Navarette and Jose Prado Navarette were arrested and charged with marijuana transportation and possession for sale.
Issues
- Whether the Fourth Amendment requires police to corroborate alleged dangerous driving before stopping a vehicle when acting on an anonymous tip.
- Whether an anonymous 911 report that a specific vehicle ran the caller off the road provides reasonable suspicion for an investigative traffic stop absent officer observation of unsafe driving.
Decision
- The Supreme Court affirmed, holding (5–4) that the stop complied with the Fourth Amendment.
- The Court concluded that, under the totality of the circumstances, the 911 report provided reasonable suspicion that the driver was intoxicated.
- The Court held that the officer was not required to observe additional suspicious driving before stopping the truck.
- The dissent argued the tip was insufficiently reliable without corroboration of criminal conduct and that corroboration of only innocent details did not justify the stop.
Legal Principles
- An investigative vehicle stop is permissible when police have a particularized, objective basis to suspect criminal activity, assessed under the totality of the circumstances, including the content and reliability of the information.
- Although anonymous tips are typically less reliable, an anonymous 911 report may supply reasonable suspicion when it contains sufficient indicia of reliability.
- Indicia supporting reliability may include a claimed eyewitness basis of knowledge, near-contemporaneous reporting, and characteristics of the 911 system that reduce the likelihood of false reports.
- Reasonable suspicion need not eliminate innocent explanations for the reported conduct, especially where the conduct described suggests an ongoing, dangerous offense such as impaired driving.
Conclusion
The Court held that an anonymous 911 call reporting a specific vehicle had run the caller off the road was sufficiently reliable, under the totality of the circumstances, to create reasonable suspicion for a traffic stop even though officers did not independently observe unsafe driving before initiating the stop.