McChesney v. State
In McChesney v. State, 988 P.2d 1071 (Wyo. 1999), the Court considered tips from an anonymous informant in an investigatory automobile stop setting.
The Court held an anonymous REDDI tip by itself was not sufficient to warrant an investigatory stop. 988 P.2d at 1077.
The Court distinguished tips from an anonymous informant from those of an identified citizen-informant, stating tips from the latter "are higher on the reliability scale because an identified informant exposes himself to possible criminal and civil prosecution if the report is false." 988 P.2d at 1076.
The Wyoming Supreme Court ruled in a sharply divided three-to-two decision that a radio dispatch of erratic driving based upon an anonymous tip was insufficient to support an investigative detention, absent some independent corroboration of the tip by the investigating officer.
In so holding, the court noted that its ruling was consistent with state highway-patrol policy that officers "will not make a stop unless police observation confirms either the report or some other illegal or suspicious activity." Id. at 1077.
In a vigorous dissent, however, two justices argued that, given the totality of the circumstances in this case, which included the description of the vehicle . . .;the location and direction of travel; the discovery by the officer of a vehicle matching that description; the arrival of that vehicle within a predictable time frame; and the clear statement of aberrant driving . . .,the officer had sufficient reasonable suspicion to accomplish an investigatory stop. Id. at 1079.