Does An Uncorroborated Anonymous Tip Regarding Criminal Activity Justify An Investigatory Stop ?
In Commonwealth v. Wimbush, 750 A.2d 807 (Pa. 2000), police proceeded to Piney Ridge Road in response to an anonymous call claiming that someone named Tony would be driving a van which contained drugs.
As Jackson and Hawkins make clear, an anonymous tip alone, given its unreliability, cannot form the basis for a reasonable suspicion that criminal activity is afoot.
Thus, the police needed "something more" than just the anonymous tip to justify conducting an investigatory stop of Wimbush.
The anonymous tip, however, was uncorroborated.
The fact that the state police learned from local authorities that Wimbush was suspected of drug activity in his county did not corroborate that he was currently engaged in drug-related activity.
The police saw no suspicious activity after it located the van and had no reason independent of the tip to believe that criminal activity was afoot.
Under Jackson, the uncorroborated anonymous tip was insufficient to create a reasonable suspicion of criminal activity and did not justify the investigatory stop.