Willamette Law Online

United States Supreme Court Certiorari Granted


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Navarette v. California

Summarized by: 

Date Filed: October 1, 2013
Case #: 12-9490
Court Below: Court of Appeals of the State of California First Appellate District Division Five (UNPUBLISHED)
Full Text Opinion: http://www.courts.ca.gov/opinions/nonpub/A132353.DOC

Criminal Procedure: Whether the Fourth Amendment requires a police officer, who receives an anonymous tip about a drunken or reckless driver, to corroborate the dangerous driving before stopping a vehicle.

Police stopped Petitioners based on an anonymous tip that Petitioners were driving recklessly. The police proceeded to investigate the vehicle and discovered marijuana. Petitioners were charged with transportation of marijuana and possession of marijuana for sale. Petitioners filed a motion to suppress the evidence, arguing that the original stop was an illegal stop because the anonymous tip was insufficient to provide reasonable suspicion of criminal activity.

The trial court denied petitioners motion to suppress, indicating that the officers corroboration of the detailed information provided in the report sufficiently verified the veracity of the tip, as required by Harvey-Madden. The Court of Appeal of the State of California First Appellate District Division Five affirmed and added that tips by citizens and victims are generally sufficient alone to satisfy reasonable suspicion, “especially if the circumstances are deemed exigent by reason of possible reckless driving or similar threats to public safety.” 

The Supreme Court granted certiorari to decide whether the Fourth Amendment requires a police officer, who receives an anonymous tip about a drunken or reckless driver, to corroborate the dangerous driving before stopping a vehicle.