Floyd v. City of Crystal Springs

In Floyd v. City of Crystal Springs, 749 So. 2d 110 (Miss. 1999), Floyd was convicted of DUI after he was stopped on a tip provided by David Rogers, a citizen who had made complaints to Officer Leflore before. Floyd, 749 So. 2d at 112. Rogers approached Officer Gerome Leflore of the Crystal Springs Police Department at a gas station on Highway 27 and told him that an antique model red Mustang convertible, traveling at a high rate of speed in a reckless manner, was headed into town on Highway 51. Id. Because Officer Leflore was off duty at the time, he called the information in to the Crystal Springs Police Department which dispatched Officer Palmer to the intersection of Highway 27 and Highway 51. Id. Palmer saw a vehicle fitting the description and ultimately stopped it. Id. In Floyd v. City of Crystal Springs, a police dispatcher was told that an automobile of a specific description and location was being driven recklessly. This justified a stop when an identical vehicle was seen. Reasonable cause for an investigatory stop may be based on an officer's personal observation or on an informant's tip if it bears indicia of reliability. Adams v. Williams, 407 U.S. at 147, 92 S. Ct. at 1924. Reasonable suspicion is dependent upon both the content of the information possessed by the detaining officer as well as its degree of reliability. Alabama v. White, 496 U.S. 325, 330 (1990). Both factors--quantity and quality--are considered in the "totality of the circumstances." Id. (Floyd, 749 So. 2d at 118.)