Does An Anonymous Tip Supported by Police Surveillance Form the Basis of Reasonable Suspision of Criminal Activity to Justify a Terry Stop ?
In Alabama v. White, 496 U.S. at 329, 110 S. Ct. 2412, the police received an anonymous tip asserting that a woman was carrying cocaine and predicting that she would leave an apartment building at a specified time, get into a car matching a particular description, and drive to a named motel. Ibid.
Standing alone, the tip would not have justified a Terry stop. Id., at 329, 110 S. Ct. 2412.
Only after police observation showed that the informant had accurately predicted the woman's movements, we explained, did it become reasonable to think the tipster had inside knowledge about the suspect and therefore to credit his assertion about the cocaine. Id., at 332, 110 S. Ct. 2412.
Although the Court held that the suspicion in White became reasonable after police surveillance, we regarded the case as borderline.
Knowledge about a person's future movements indicates some familiarity with that person's affairs, but having such knowledge does not necessarily imply that the informant knows, in particular, whether that person is carrying hidden contraband.
The Court accordingly classified White as a "close case." Ibid.