## 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

1. Whether the Fourth Amendment requires police to corroborate alleged dangerous driving before stopping a vehicle when acting on an anonymous tip.
2. 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.


Navarette v. California, 572 U.S. 393 (2014)