Florida v. J.L.
529 U.S. 266, 120 S. Ct. 1375, 146 L. Ed.2d 254 (2000)

  • The police got an anonymous tip that a juvenile (J.L.) was loitering at a bus stop carrying a concealed weapon.
  • The police went to the bus stop, found J.L., frisked him, and found a gun. He was arrested and charged with carrying a concealed weapon.
    • The police relied on the stop and frisk rules, which requires only that they have reasonable suspicion that the suspect is armed. They do not need probable cause. That’s known as a Terry stop.
      • See Terry v. Ohio (392 U.S. 1 (1968)).
  • At Trial, J.L. made a motion to suppress the evidence.
    • J.L. argued that even under the lower standard, the police did not have reasonable suspicion.
  • The Trial Court granted the motion and suppressed the evidence. The prosecutor appealed.
  • The Appellate Court reversed. J.L. appealed.
  • The Florida Supreme Court reversed the Appellate Court and suppressed the evidence. The prosecutor appealed.
    • The Florida Supreme Court found that this search was a violation of J.L.’s 4th Amendment rights.
  • The US Supreme Court affirmed.
    • The US Supreme Court found that a stop and frisk search can only occur when there is reasonable suspicion that the suspect is armed and dangerous. In this case, the anonymous tip by itself was not sufficient to establish reasonable suspicion.
      • J.L. was just hanging around, he wasn’t doing anything suspicious.
    • The Court found that in order to justify the search, the police needed to verify the credibility of the informant and the information given or the tip needed to be corroborated with some sort of unusual conduct by the suspect that would reasonably lead an officer to conclude that criminal activity could be afoot.
  • This reasoning is comparable to the Court’s treatment of anonymous sources and probable cause in Illinois v. Gates (462 U.S. 231 (1983)).
    • The difference is that here, J.L. wasn’t doing anything unusual, and that nature of the prediction in this case did not give rise to the belief that the tipster had any inside knowledge about J.L.
      • An anonymous source is valid only if the information they provide could only have come from someone who has inside knowledge.
        • Anyone could have noticed that J.L. was standing there, it wasn’t predictive, and so didn’t imply that the tipster actually knew anything about J.L. If the tipster said that J.L. would arrive at the bus stop at a certain time wearing a certain shirt, that would have been more valid because it implies that the tipster knew J.L. personally.