State v. Zapata

In State v. Zapata, 297 N.J. Super. 160, 173, 687 A.2d 1025 (App.Div.1997) certif. denied, 156 N.J. 405, 719 A.2d 637 (1998), the Court found that "an anonymous call may provide the factual predicate to justify an investigatory stop when there is corroboration of the information furnished." See Alabama v. White, 496 U.S. 325, 329, 110 S. Ct. 2412, 2415-16, 110 L. Ed. 2d 301, 308 (1990) (finding that a telephone tip from an unknown informant does not provide the objectively reasonable suspicion required for a Terry stop and frisk unless it is corroborated by other evidence). Judge Michels, writing for the panel, found that where the reliability of the anonymous tip is established through independent police work, investigatory stops based on such tips are permissible. Zapata, 297 N.J. Super. at 173, 687 A.2d 1025. In that case the Court adopted a totality of the circumstances approach to determine whether reasonable suspicion was established to justify an investigatory stop. Id. at 172, 687 A.2d 1025.