Navarette v. California

In Navarette v. California, 134 S. Ct. 1683, 188 L. Ed. 2d 680 (2014), a 911 caller, presumed by the court to be anonymous, reported that a vehicle ran her car off the road. The caller provided the location as well as a description of the vehicle and license plate number. The 911 dispatcher relayed the information to officers. 134 S. Ct. at 1686-87. About eighteen minutes later, officers spotted a vehicle some nineteen miles south of the location reported in the tip. Id. at 1689. The officers pulled the truck over. As they approached, they smelled marijuana and a subsequent search revealed 30 pounds of marijuana in the bed of the truck. Id. at 1687. The court held the anonymous tip contained adequate indicia of reliability to support reasonable suspicion because the content of the tip indicated it: (1) was based on eyewitness knowledge, which "lends significant support to the tip's reliability"; (2) was contemporaneously made, which is "especially trustworthy because 'substantial contemporaneity of event and statement negate the likelihood of deliberate or conscious misrepresentation'"; (3) was made to the 911 emergency system, which "has some features that allow for identifying and tracing callers, and thus provide some safeguards against making false reports with immunity." Navarette, 134 S. Ct. at 1689-90. In sum, a 911 caller reported that a driver in a silver Ford 150 pickup ran her vehicle off the roadway near a specific mile marker five minutes earlier while driving southbound on Highway 1, and she provided the truck's license plate information. Navarette, 134 S. Ct. at 1686-87. Law enforcement detained the pickup truck driver less than twenty minutes later on southbound Highway 1, as reported by the 911 caller. Id. The Supreme Court held that the caller's tip contained adequate indicia of reliability to support reasonable suspicion because the content of the tip indicated that it was based on eyewitness knowledge, was contemporaneously made, and was made to the 911 emergency system. Id. The Supreme Court also found persuasive the fact that the 911 caller in Navarette reported "more than a minor traffic infraction and more than a conclusory allegation of drunk or reckless driving. Instead, she alleged a specific and dangerous result of the driver's conduct: running another car off the highway. That conduct bears too great a resemblance to paradigmatic manifestations of drunk driving to be dismissed as an isolated example of recklessness. Running another vehicle off the road suggests lane-positioning problems, decreased vigilance, impaired judgment, or some combination of those recognized drunk driving cues." Id. at 1691. The Court reasoned that "reasonable suspicion depends on 'the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act' and under that commonsense approach, we can appropriately recognize certain driving behaviors as sound indicia of drunk driving." Id. at 1690.