Alabama v. White

Alabama v. White Case Brief

United States Supreme Court
496 U.S. 325 (1990)

ISSUE: Did an officer have reasonable suspicion sufficient to justify a Terry stop when the police received an anonymous phone tip that D would be carrying cocaine and not all of the information in the tip checked out?
HOLDING: Yes.
FACTS:
  • Police received an anonymous tip that White would be leaving an apartment complex in a brown Plymouth with the right taillight broken and she'd be driving to a motel with an ounce of cocaine in a brown attache case
  • 2 officers went to the apartments, saw go to a brown Plymouth, and drive in the direction of the motel -- she was carrying nothing
  • Officer stopped the car, asked White for permission to search the car, and found marijuana in the attache case
  • Upon processing at the station, officers found cocaine in D's purse
PROCEDURAL HISTORY:
  • Trial Ct. refused to suppress
  • Ct. App. reversed holding that there was no reasonable suspicion
  • Ala. Sup. Ct. denied cert.
RULES:
  • Illinois v. Gates: Abandoned two-pronged Aguilar-Spinelli test in favor of a "totality of the circumstances" approach to determining whether an informant's tip establishes PC
    • Informant's veracity, reliability, and basis of knowledge remain highly important factors
REASONING:
  • Tip alone didn't provide reasonable suspicion: The tip provided virtually nothing from which one might conclude that the caller is either honest or his information is reliable, and it gives no indication of the basis of knowledge for the caller's predictions
    • Tip would not warrant a man of reasonable caution in the belief that a stop was appropriate
  • Reasonable suspicion established: The subsequent corroboration of some info in the tip provided the officers with reasonable suspicion to pull D's car over
    • Reasonable suspicion, like PC, is dependent upon both the content of the information possessed by the police and its degree of reliability -- quantity and quality
    • Not every detail checked out, but the tipster obviously had an close enough relationship in order to predict such intimate details
DISSENT - Stevens: The tipster might well have been another police officer who had a "hunch" that D might have cocaine in her attache case

 

Leave a Reply