Page 16 - North Carolina 2020 Legal Guide

Task: Stop Based on Anonymous Tip

Navarette v. California, 134 S. Ct. 1683 (U.S. 2014).

• Anonymous reports may support reasonable suspicion to make a

vehicle stop however two essential components must be met:

• The anonymous report must have some indicia of reliability going

beyond simply describing location and description. Such as

Reporting in First Person that they were actual witness.

• The reliable anonymous information must add up to reasonable

suspicion to believe that criminal activity is afoot.

• Here, the Court placed an indication of reliability, on the fact that the

caller used the 911 system to make the call such that the caller

would assume their call was traceable and thus less likely to falsely

report

©2020 Jack Ryan Legal & Liability Risk Management Institute 15