State v. Altieri
In State v. Altieri, 191 Ariz. 1,951 P.2d 866 (1997), the Arizona Department of Public Safety received an anonymous tip claiming that a man was driving a car containing 150 pounds of marijuana. 191 Ariz. 1, P 2, 951 P.2d at 867.
The informant provided the name and age of the driver; the make, model, appearance, and license plate number of the vehicle; and the vehicle's approximate location. Id.
Officers located and stopped the car based solely on this information. Id. P 3.
On appeal, Altieri contended the tip was insufficient to provide reasonable suspicion to stop his vehicle.
The court of appeals affirmed the trial court's denial of his motion to suppress, and the supreme court reversed. Id. PP 5-6.
The supreme court acknowledged that "an anonymous tip may, in some circumstances, be sufficient to support a stop, if it . . . shows sufficiently detailed circumstances to indicate that the informant came by his information in a reliable way." Id. P 9.
And it noted that when the tip "fails to provide sufficient underlying circumstances demonstrating the reliability of the information, the reliability may be supplied by independent observations of the police corroborating the information in the tip." Id.
However, to provide reasonable suspicion, the tip "must contain 'a range of details relating not just to easily obtained facts and conditions existing at the time of the tip, but to future actions of third parties ordinarily not easily predicted.'" Altieri, 191 Ariz. 1, P 9, 951 P.2d at 868.
Ultimately, the supreme court concluded the tip leading to Altieri's arrest did not provide reasonable suspicion for the initial stop, because it contained only "neutral, non-predictive information about the defendant and his activities." Id. P 14.