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Ep. #342: Anonymous 911 calls and vehicle stops?
📌 Assuming that motorist's 911 emergency call, reporting that a pickup truck had run her off the road, was anonymous, her tip was sufficiently reliable, for purposes of reasonable suspicion for a traffic stop of pickup truck; motorist, by describing the brand name and model for the pickup truck and the truck's license plate number, necessarily claimed eyewitness knowledge of alleged dangerous driving, the timeline of events, with police locating the pickup truck 18 minutes after the 911 call, suggested that motorist reported the incident soon after she was run off the road, and motorist's use of 911 system provided another indicator of her veracity, since that system had features that allowed for identifying and tracing callers, thereby providing some safeguards against making false reports.
- Navarette v. California, 572 U.S. 393, 134 S. Ct. 1683, 188 L. Ed. 2d 680 (2014)
📌 While tip such as 911 call may generate reasonable suspicion for investigative stop, it can only do so when, under totality-of-the-circumstances, it possesses two features: (1) tip must exhibit sufficient indicia of reliability, and (2) it must provide information on potential illegal activity serious enough to justify stop.
- United States v. Vandergroen, 964 F.3d 876 (9th Cir. 2020)
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