Alabama v. White – Case Brief Summary (U.S. Supreme Court)

In Alabama v. White, 496 U.S. 325 (1990), the police received an anonymous tip that a woman was carrying about an ounce of cocaine in an attache case. The informant explained that the woman would leave her apartment at a specified time, get into a car matching a specified description, and drive to a particular motel. Acting on the tip, the police conducted surveillance and observed the woman proceed as predicted. They followed her as she took the most direct route to the motel identified in the tip, and stopped her just short of the predicted destination. The officers searched the vehicle with the woman's permission, and marijuana was found in an attache case. The woman was arrested and, during processing at the station, officers found three milligrams of cocaine in her purse. (Alabama, supra, 496 U.S. at p. 327.)

The high court concluded that, while a "close case," and while the anonymous tip alone did not justify the stop, the tip, coupled with observations of the defendant's movements in accordance with the informant's predictions, made it reasonable to believe the informant had inside information about the suspect and therefore credit his assertion about illegal activity. (Id. at p. 332.)

The United States Supreme Court was satisfied that although not every detail mentioned by the anonymous caller was verified by the police, they did corroborate the fact that the suspect left a building that the caller said she would leave in a particular vehicle that was described by the caller.

In addition, the caller gave a particular time when the suspect would be leaving, and the suspect was observed traveling in the direction of the predicted destination, although the officers stopped her short of that destination.

Considering the totality of the circumstances, and the fact that the tip involved future actions of the suspect, ordinarily not easily predicted, the Supreme Court held that the anonymous tip, as corroborated, was supported by sufficient indicia of reliability and justified the investigatory stop of the vehicle.

The Court applied the "totality of circumstances" standard articulated in Illinois v. Gates (1983) 462 U.S. 213, to determine that there was objectively reasonable suspicion for a stop based on an anonymous tip. (White, at p. 328.)

As noted, in White, a police officer received a telephone call from an anonymous person, who stated that White would be leaving a specific apartment building at a particular time in a particular vehicle to go to a motel in possession of an ounce of cocaine in a brown attach? case. (Id. at p. 326.)

The officer and a partner went to the apartment building, and observed White leave the building with nothing in her hands and enter the car, which was in the building parking lot. (Ibid.) They followed the vehicle as it took the most direct route towards the motel, and ordered a stop of the vehicle just short of that motel. (Ibid.)

Based on these facts, the Supreme Court concluded that, while "not every detail mentioned by the tipster was verified" (White, supra, 496 U.S. at p. 331) and the case was "close" (id. at p. 332), "when the officers stopped White, the anonymous tip had been sufficiently corroborated to furnish reasonable suspicion that White was engaged in criminal activity and that the investigative stop therefore did not violate the Fourth Amendment." (Id. at p. 331.)

The White court noted that the court in Illinois v. Gates, supra, 462 U.S. 213, "gave credit to the proposition that because an informant is shown to be right about some things, he is probably right about other facts that he has alleged, including the claim that the object of the tip is engaged in criminal activity. Thus, it is not unreasonable to conclude in this case that the independent corroboration by the police of significant aspects of the informer's predictions imparted some degree of reliability to the other allegations made by the caller." (Id. at pp. 331-332.)

The court thought it particularly important that the caller had predicted White's future behavior, since this showed "a special familiarity with White's affairs." (Id. at p. 332.) "Because only a small number of people are generally privy to an individual's itinerary, it is reasonable for police to believe that a person with access to such information is likely to also have access to reliable information about that individual's illegal activities. When significant aspects of the caller's predictions were verified, there was reason to believe not only that the caller was honest but also that he was well informed, at least well enough to justify the stop." (Ibid.)

The Supreme Court upheld an investigative detention of a motorist and resulting seizure of drugs from her car where an anonymous tip predicting the motorist's departure from a specific location in a particularly described car, heading with cocaine to a certain destination, was substantially corroborated by police observation. ( Id. at pp. 331-332.)

In concluding the tip was sufficiently corroborated to create the necessary reasonable suspicion for an investigative stop, the court gave particular weight to the tipster's description of "'future actions of third parties ordinarily not easily predicted.' . . .

Because only a small number of people are generally privy to an individual's itinerary, it is reasonable for police to believe that a person with access to such information is likely to also have access to reliable information about that individual's illegal activities." ( Id. at p. 332.)

In other words, the tipster's knowledge of the suspect's imminent departure, car, and destination was enough to suggest the caller had personal knowledge of her drug possession too.

See also People v. Ramirez (1996) 41 Cal.App.4th 1608, 1616 (anonymous tipster's prediction of suspect's future behavior, subsequently verified by police observation, is circumstance supporting reliability of informant's information).

The Court held that police were justified in stopping the woman just before arriving at her destination because police corroboration of the facts reported by the anonymous tipster established sufficient indicia of reliability.

The Court stated that, standing alone, the tip received by police was completely lacking in the necessary indicia of reliability because it provided virtually nothing from which one might conclude that the caller was honest or his information reliable and gave no indication of the basis for the tipster's predictions regarding White's criminal activities. Although it was a close question, the Court held that the totality of the circumstances demonstrated that significant aspects of the informant's story were sufficiently corroborated by the police to furnish reasonable suspicion.

Thus, although an anonymous tip standing alone is generally insufficient, it may contribute to the necessary reasonable suspicion when coupled with the officer's own corroboration of significant details of the tip.

The United States Supreme Court found that the verification of those facts coupled with the verification of the destination of the defendant lent sufficient credibility to the anonymous tip to warrant a reasonable and articulable suspicion. Id., 332.

The court stated: "What was important was the caller's ability to predict respondent's future behavior, because it demonstrated inside information -- a special familiarity with respondent's affairs. The general public would have had no way of knowing that respondent would shortly leave the building, get in the described car, and drive the most direct route to Dobey's Motel. . . . When significant aspects of the caller's predictions were verified, there was reason to believe not only that the caller was honest but also that he was well informed, at least well enough to justify the stop." Id.

As the court explained its reasoning: "'The anonymous tip contained a range of details relating not just to easily obtained facts and conditions existing at the time of the tip, but to future actions of third parties ordinarily not easily predicted.' The fact that the officers found a car precisely matching the caller's description in front of the designated building is an example of the former. Anyone could have 'predicted' that fact because it was a condition presumably existing at the time of the call. What was important was the caller's ability to predict respondent's future behavior, because it demonstrated inside information--a special familiarity with respondent's affairs. The general public would have had no way of knowing that respondent would shortly leave the building, get in the described car, and drive the most direct route to the identified motel. Because only a small number of people are generally privy to an individual's itinerary, it is reasonable for police to believe that a person with access to such information is likely to also have access to reliable information about that individual's illegal activities. When significant aspects of the caller's predictions were verified, there was reason to believe not only that the caller was honest but also that he was well informed, at least well enough to justify the stop." (Alabama, supra, 496 U.S. at p. 332 110 L.Ed.2d at p. 310.)

While restating the general rule that an anonymous tip alone lacks sufficient indicia of reliability to support a detention, the Supreme Court found that the tip here provided more. The content of the tip itself carried sufficient indicia of reliability when corroborated by the officers' observation to furnish reasonable suspicion of criminal activity. ( Id. at pp. 329-331.)

In upholding the detention, the court found it important to note that the anonymous tip contained a range of details relating not just to easily obtained facts and conditions existing at the time of the tip, but to future actions of third parties that are ordinarily not easily predicted. ( Id. at p. 332.)

It was the combination of the caller's ability to predict White's future behavior and the verification of such information by police observation that provided the indicia of reliability sufficient to justify the investigatory stop. (Ibid.)