Navarette v. California

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Procedure
  • Date Filed: April 22, 2014
  • Case #: 12-9490
  • Judge(s)/Court Below: THOMAS, J., delivered the opinion of the Court, in which ROBERTS, C. J., and KENNEDY, BREYER, and ALITO, JJ., joined. SCALIA, J., filed a dissenting opinion, in which GINSBURG, SOTOMAYOR, and KAGAN, JJ., joined
  • Full Text Opinion

An anonymous call can provide officers with reasonable suspicion to make an investigatory stop of a person driving under the influence when the caller has a sufficient eyewitness basis of knowledge.

California Highway Patrol (CHP) officers, responding to an anonymous 911 call reporting erratic driving, conducted a traffic stop on Petitioner’s vehicle, which matched the description from the 911 call. The 911 call described the license plate, vehicle make, color, and direction the vehicle was moving. During the stop, CHP officers smelled marijuana, then conducted a search of the vehicle and found 30 pounds of marijuana. The driver and passenger of the vehicle, Petitioners, were arrested.

Petitioners moved to suppress evidence from the traffic stop, arguing that the arresting officers lacked reasonable suspicion of criminal activity. The magistrate presiding over the suppression hearing, and the Superior Court denied the motion, and the California Court of Appeals upheld the lower court’s motion. The California Supreme Court denied review. The United States Supreme Court granted certiorari on the question of whether an officer is required to corroborate an anonymous tip of dangerous driving before stopping a vehicle.

The Supreme Court held that an anonymous tip “can demonstrate sufficient indicia of reliability to provide reasonable suspicion to make an investigatory stop.” The caller reported that she was run off the road by Petitioner, and thus had eyewitness knowledge. In addition, under the totality of the circumstances, the officer had reasonable suspicion that the driver was driving while intoxicated.

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