Alabama v. White

Supreme Court of United States
496 U.S. 325 (1990)

ELI5:

Rule of Law:

An anonymous tip can provide reasonable suspicion for an investigatory stop if it is sufficiently corroborated by independent police work to exhibit adequate indicia of reliability. Corroboration of an informant's ability to predict a suspect's future behavior is particularly important in establishing the tip's credibility.

Facts:

An anonymous person telephoned the Montgomery Police Department with a detailed tip about Vanessa White.
The tipster stated White would leave apartment 235-C at Lynwood Terrace Apartments at a particular time and get into a brown Plymouth station wagon with a broken right taillight.
The caller predicted White would then drive to Dobey's Motel and would be in possession of an ounce of cocaine inside a brown attaché case.
Police officers went to the apartment complex and observed a brown Plymouth station wagon with a broken right taillight parked in front of the 235 building.
The officers saw Vanessa White leave the building, empty-handed, get into the station wagon, and begin driving.
The officers followed White as she drove the most direct 4-mile route toward Dobey's Motel.
Police initiated a traffic stop of White's vehicle just before she reached the motel.
After obtaining White's consent to search the car, officers found a locked brown attaché case containing marijuana, and later found cocaine in her purse at the station.

Procedural Posture:

Vanessa White was charged with possession of marijuana and cocaine in Montgomery County Court, a state trial court.
The trial court denied White's motion to suppress the evidence obtained from the stop.
White pleaded guilty but reserved the right to appeal the trial court's denial of her suppression motion.
On appeal, the Court of Criminal Appeals of Alabama, an intermediate appellate court, reversed the conviction, holding that the investigatory stop was not supported by reasonable suspicion.
The Supreme Court of Alabama, the state's highest court, denied the State of Alabama's petition for a writ of certiorari.
The State of Alabama (petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the decision of the Alabama Court of Criminal Appeals.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does an anonymous telephone tip that is significantly corroborated by independent police observation of details, including predictive information about a suspect's future actions, exhibit sufficient indicia of reliability to provide reasonable suspicion for an investigatory stop under the Fourth Amendment?

Opinions:

Majority - Justice White

Yes, an anonymous telephone tip sufficiently corroborated by police work can provide the reasonable suspicion needed for an investigatory stop. Although reasonable suspicion requires more than a mere hunch, it is a less demanding standard than probable cause and can be satisfied with information that is less reliable. While an anonymous tip alone is rarely sufficient because the informant's veracity and basis of knowledge are unknown, it can become reliable if police corroborate its details. In this case, the police corroborated not only present facts (the car's description and location) but also the informant's predictions of White's future behavior (leaving the apartment and driving toward the motel). This ability to predict future actions indicated the informant had inside knowledge of White's affairs, which made it reasonable for police to believe the informant was also correct about the allegation of criminal activity. Under the totality of the circumstances, the corroborated tip exhibited sufficient indicia of reliability to justify the stop.

Dissenting - Justice Stevens

No, this anonymous tip, even as corroborated, did not provide reasonable suspicion for the stop. The corroborated facts—leaving an apartment building and driving to a motel—were innocent, mundane details that any neighbor, acquaintance, or person with a grudge could know. The tipster was even wrong about a key detail, as White was not carrying the attaché case when she left the apartment. Allowing stops based on such easily obtainable information makes citizens vulnerable to police seizures based on pranks or malicious falsehoods. This ruling weakens the Fourth Amendment's protection against overzealous law enforcement by validating stops based on hunches disguised as anonymous tips.

Analysis:

This decision clarifies how the 'totality of the circumstances' test from Illinois v. Gates applies to the lower standard of reasonable suspicion for investigatory stops. It establishes a significant precedent that the corroboration of an anonymous tip's predictive details about future, innocent behavior can make the entire tip, including its criminal allegations, sufficiently reliable to justify a stop. This holding provides law enforcement with a clearer framework for acting on anonymous tips, but it has been criticized for potentially lowering the bar for what constitutes a constitutional seizure. The case distinguishes between the value of corroborating existing, public facts and the greater value of corroborating future actions, which implies a special familiarity with the suspect's affairs.

Gunnerbot

AI-powered case assistant

Loaded: Alabama v. White (1990)

Try: "What was the holding?" or "Explain the dissent"