Whether an anonymous 911 tip that implies the person sold drugs in a public area provides reasonable suspicion to seize the person without first corroborating the claim of illegality

QUESTION PRESENTED An anonymous tip must either be reliable on its own or be adequately corroborated before it can provide reasonable suspicion to seize a person. This Court has analyzed a range of tips from a “bare report” that “surely” fell on the side of the line, Florida v. J.L., 529 U.S. 266, 271 (2000), to tips that, under the totality of circumstances, provided reasonable suspicion in “close” or “borderline” cases, Navarette v. California, 572 U.S. 393, 404 (2014); Alabama v. White, 496 U.S. 325, 332 (1990). Despite these guideposts, courts continue to struggle with the spectrum when it comes to anonymous tips. Meanwhile, law enforcement is increasingly encouraging and using anonymous tips—including via 911. The question presented here is: If an anonymous 911 tipster implies that he saw a person sell drugs in a bustling public area, may officers seize the person without first corroborating the tipster’s claim of illegality? i