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

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

 

Facts: In August of 2008, an anonymous 911 call was made in a northern California county reporting that a silver Ford pickup truck had run the caller off the road while heading south on Highway 1. The caller provided the license plate number and the mile marker at which the incident occurred. Eighteen minutes after the call, police spotted the Ford truck 19 miles south of the location and decided to follow it for a few miles. When the officers did not observe any erratic driving behavior, they decided to pull the vehicle over. While talking to the driver, they smelled marijuana and subsequently conducted a search of the automobile. Four large bags of marijuana, amounting to thirty pounds, were found in the bed of the truck, and the two occupants of the vehicle were arrested for transportation of marijuana and possession of marijuana for sale. 

 

Procedural History: At the trial, the defendants moved to suppress the evidence on the grounds that the stop was made without reasonable suspicion. Their motion was denied as the state argued that the anonymous tip of reckless driving and the matching details constituted reasonable suspicion. The defendants subsequently plead guilty. The California Court of Appeal affirmed the trial court’s decision, and the California Supreme Court denied review. The United States Supreme Court then granted certiorari.

 

Issue: Is the investigative traffic stop carried out by an officer following an anonymous tip of erratic driving, or some other form of potential criminal behavior, conducted with reasonable suspicion in accordance with the Fourth Amendment’s protection against unreasonable searches and seizures? 

 

Holding: Yes, an anonymous tip with a basis of credibility is sufficient enough to constitute reasonable suspicion in order to conduct an investigative stop without violating the suspect’s Fourth Amendment rights. Extended observation might have dispelled the reasonable suspicion, but in this case, it was only a five-minute period of subsequent observation following the tip, so it did not suffice. 

 

Reasoning: In this case, the Supreme Court held that the officers had reasonable suspicion to justify the traffic stop as permitted by the Fourth Amendment’s protection against unreasonable searches and seizures. In deciding this case, the Court used their prior decisions in Alabama v. White and Florida v. J.L. as guides. Both of these cases involved anonymous tips of criminal behavior that resulted in police involvement. In these cases, they recognized that a tipster who “is proved to tell the truth about some things is more likely to tell the truth about other things”, specifically the claim regarding criminal behavior. They also noted that in order for the tip to amount to reasonable suspicion sufficient enough to conduct a stop, there must be some basis of credibility in regard to the informant. Such a basis may include an explanation of how the tipster knows the information, details that prove familiarity with the suspect’s affairs, and/or any predictions of the suspect’s future behavior. Due to these cases’ rulings, the Court felt the anonymous caller, and their provision of the specific vehicular information, had claimed eyewitness knowledge of the erratic driving, allowing for a basis of knowledge to support their claim. The police had also located the truck eighteen minutes after the call, nineteen miles south of the location designated in the call. This information further supported the facts of the initial reported incident. The Court ultimately concluded that all this information considered together amounted to reasonable suspicion to justify an investigative traffic stop. Along with this, the Court stated that extended observation of the vehicle to which the suspicion is directed may dispel the reasonable suspicion present when the vehicle is first spotted. However, in this case it was only a brief five-minute period of observation, and unnecessary observation at that, as reasonable suspicion already existed. 

The officers therefore had reasonable suspicion in accordance with the Fourth Amendment to conduct an investigative stop of the vehicle. The decision of the California Court of Appeals was affirmed.