Difference Between Reliability of Unknown Person Who Informs Police About a Crime In Person and An Anonymous Police Phone Call

In In re A.V., 336 Ill. App. 3d 140, 144, 783 N.E.2d 111, 270 Ill. Dec. 536 (2002), this court distinguished unknown individuals who approach police officers in person with information about criminal activity from unknown individuals who anonymously telephone tips. In that case, a teenager approached a police officer who was patrolling an area of a park to say that "a kid," a husky 16-year-old Hispanic boy wearing black jeans, a blue shirt and white gym shoes, was showing a gun to other "young people." In re A.V., 336 Ill. App. 3d at 141. The informant indicated the direction in which the 16-year-old was located. The officer, heading towards the area of the suspect, was stopped by several others who also told him about a boy showing a gun. The officer then stopped the respondent, who matched the description but was not doing anything illegal, within about a minute and 200 feet from where he was first informed. The officer conducted a pat-down and recovered a loaded gun. This court affirmed the trial court's denial of the respondent's motion to suppress, concluding that the information provided to the officer contained the requisite indicia of reliability. The Court explained that although the informants' names were unknown, the informants "were not anonymous in the same sense as the caller in J.L.." In re A.V., 336 Ill. App. 3d at 144. This court noted that the informants were "identifiable" (In re A.V., 336 Ill. App. 3d at 144) because they approached the officers and spoke to them in person. Further, the informants were still in the park where the incident occurred when they spoke to the police, and the information they provided was timely, as the respondent was stopped within one minute of the officer's receipt of the information. The Court also found that in that case, and contrary to in J.L., the informants were "physically present" (In re A.V., 336 Ill. App. 3d at 144) and not untraceable as the officers could have easily found the informants had their information proved false. Further, the original informant's tip was corroborated by several other people.