Lexplug logoLexplug

Florida v. J. L.

Supreme Court of the United States
529 U.S. 266 (2000)
ELI5:

Rule of Law:

An anonymous tip that a person is carrying a gun is not, without more, sufficient to justify a police officer's stop and frisk of that person under the Fourth Amendment.


Facts:

  • On October 13, 1995, an anonymous person called the Miami-Dade Police.
  • The caller reported that a young black male, who was standing at a specific bus stop and wearing a plaid shirt, was carrying a gun.
  • Police officers arrived at the bus stop approximately six minutes later and saw three black males.
  • One of the males, J.L., was wearing a plaid shirt.
  • The officers did not observe a firearm or any threatening or unusual movements from J.L. or the others.
  • Apart from the anonymous tip, the officers had no independent reason to suspect any of the individuals of illegal conduct.
  • One officer approached J.L., instructed him to put his hands up on the bus stop, and conducted a frisk.
  • The officer seized a gun from J.L.'s pocket.

Procedural Posture:

  • J.L. was charged under Florida state law with carrying a concealed firearm without a license and possession of a firearm while under the age of 18.
  • At the trial court level, J.L. moved to suppress the gun as the fruit of an unlawful search, and the court granted his motion.
  • The State of Florida, as appellant, appealed the suppression order to the intermediate appellate court, which reversed the trial court's decision.
  • J.L., as appellant, then appealed to the Supreme Court of Florida.
  • The Supreme Court of Florida quashed the decision of the intermediate appellate court, holding that the search was invalid under the Fourth Amendment.
  • The State of Florida, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court to review the judgment of the Florida Supreme Court.

Locked

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 tip that a person is carrying a gun, without any further corroboration or indicia of reliability, provide sufficient reasonable suspicion to justify a police officer's stop and frisk of that person under the Fourth Amendment?


Opinions:

Majority - Justice Ginsburg

No. An anonymous tip that a person is carrying a gun, lacking sufficient indicia of reliability, does not justify a stop and frisk. Unlike a tip from a known informant, an anonymous tip provides no basis to assess the informant's credibility or basis of knowledge. To establish reasonable suspicion, a tip must be reliable in its assertion of illegality, not just in its tendency to identify a determinate person. The tip concerning J.L. provided no predictive information that would allow police to test the informant's knowledge, distinguishing it from the tip in Alabama v. White, which the Court had already deemed a 'close case.' The Court rejected Florida's proposal for a 'firearm exception' to the standard reliability analysis, reasoning that such an exception would invite harassment through false anonymous calls and could easily be extended to other alleged crimes, thereby swallowing the general rule.


Concurring - Justice Kennedy

No. The majority opinion is correct on the facts of this case. A truly anonymous tip is unreliable because the informant has not placed their credibility at risk and can lie with impunity. However, some anonymous tips might have features that provide reliability. For example, a tip that predicts future conduct, a recurring anonymous caller who has been reliable in the past, or a tip where police can trace the call or record the voice might justify a police response. In this case, the record provided no such indicia of reliability, so the stop and frisk was unjustified.



Analysis:

This case significantly clarifies the requirements for establishing reasonable suspicion based on anonymous tips, reinforcing the precedent set in Alabama v. White. By explicitly rejecting a 'firearm exception' to the Terry standard, the Court affirmed that the nature of the alleged crime does not lower the Fourth Amendment's demand for proven reliability in an informant's tip. The decision mandates that law enforcement corroborate an anonymous tip's assertion of concealed criminal activity, not just its description of a person's appearance, thereby protecting individuals from intrusive searches based on unverified and potentially malicious accusations. This holding creates a clear line against stops based on bare-bones anonymous information, forcing police to observe predictive behavior or find other corroboration before conducting a frisk.

🤖 Gunnerbot:
Query Florida v. J. L. (2000) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.
Locked
Subscribe to Lexplug to chat with the Gunnerbot about this case.

Unlock the full brief for Florida v. J. L.