Gabriel Samar Martinez v. United States
FourthAmendment CriminalProcedure Privacy JusticiabilityDoctri
Whether an uncorroborated anonymous tip, standing alone, can give rise to reasonable suspicion to justify a seizure
QUESTION PRESENTED Law enforcement stopped the Petitioner based on a brief, uncorroborated tip from an anonymous motorist that the person in a white vehicle had pointed a gun at him. Rather than pull over to speak with law enforcement, the motorist drove off, leaving officers with absolutely no information that would permit them to identify, contact, or track down the motorist. The motorist’s tip did not report an “ongoing” crime, like drunk driving, nor did it involve a 911 call system or other technology that would provide “safeguards against making false reports with immunity.” Navarette v. California, 572 U.S. 393, 400, 402 (2014). The only corroboration of the barebones tip—the description of the vehicle—was the type rejected by this Court in Florida v. J.L.: corroboration of innocent, readily observable information that tends to identify a particular person but fails to bolster the reliability of the tip in its assertion of illegality. Florida v. J.L., 529 U.S. 266, 272 (2000). As a result, the tip failed to establish reasonable suspicion, and the seizure was unlawful. The Eleventh Circuit, however, held differently below, putting it at odds with this Court’s Fourth Amendment jurisprudence. The question presented is: Whether an uncorroborated anonymous tip, standing alone, can give rise to reasonable suspicion to justify a seizure. ‘