Anonymous Tip of Drug-dealing Case in California

In People v. Butler (2003) 111 Cal.App.4th 150, an officer received a bulletin at approximately 6:30 p.m. about an anonymous tip that drugs were being sold out of a grey Ford Explorer at a particular address known to the officer to be in a high-crime area. When the officer reached the address, he saw a grey Ford Explorer with the driver's window down. He witnessed the defendant, in the driver's seat, hand something to a woman standing outside the car, and she handed something back to him. (Id. at p. 156.) The Court of Appeal found that the combination of the anonymous tip of drug-dealing and the officer's observation of an exchange fully consistent with the details of the tip was sufficient to create a reasonable suspicion of criminal activity. (Id. at pp. 161-162.)