State v. Gomez
In State v. Gomez, 198 Ariz. 61, 6 P.3d 765 (App. 2000), an unidentified caller stated she had observed a passenger in a vehicle pointing a gun out of the window and waving it in the air. 198 Ariz. 61, P 3, 6 P.3d at 766.
The caller provided identifying information about the vehicle, and an officer located and stopped the vehicle. Id. After arresting the passenger for an outstanding warrant, officers searched him and found drugs and drug paraphernalia in one of his socks. Id.
Relying on State v. Altieri, Gomez asserted the police lacked reasonable suspicion to stop the vehicle in which he was a passenger. Id. P 9.
The state argued Altieri was distinguishable because the tip had been provided by a "'citizen complaint' rather than a mere 'anonymous tip.'" Id. P 15.
The court noted in Gomez that prior cases had suggested "'reliability is enhanced' when 'an ordinary citizen volunteers information which he has come upon in the ordinary course of his affairs, completely free of any possible ordinary gain.'" Id.