James v. State, 197 So. 3d 532

At 1:30 a.m., Montgomery police received an anonymous tip reporting a black Impala at a truck stop with female prostitutes and two armed male occupants. Detective Harrison located the Impala with two Black men inside but observed nothing else corroborative.
After backup arrived, Detective Harrison ordered the occupants out to perform a wingspan (frisk) search, citing the tip that the occupants were armed.
When James stepped out, the officer observed a small plastic baggy in the front passenger door pocket containing narcotics.
James pleaded guilty but preserved his right to appeal denial of his motion to suppress the narcotics, arguing the warrantless detention and extraction from the car lacked reasonable suspicion.
The trial court denied the suppression motion; on appeal the Alabama Court of Criminal Appeals reviewed the undisputed facts de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ordering James out of the car based solely on an anonymous tip was a seizure violating the Fourth Amendment	James: the anonymous tip was unverified and unreliable, so there was no reasonable suspicion to detain or order him out	State: the tip plus officer’s experience and the high-crime location justified a wingspan search to check for weapons	The stop was a seizure and, under the totality of circumstances, the uncorroborated anonymous tip did not supply reasonable suspicion; detention was unconstitutional
Whether evidence (drugs) discovered after the detention must be suppressed as fruit of an unlawful seizure	James: the drugs were discovered only because of the illegal detention, so they are inadmissible	State: (implicit) discovery was lawful because officer acted on tip and safety concerns	Held: the narcotics were the fruit of the unconstitutional detention and must be suppressed

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (permits brief investigatory stops based on reasonable suspicion)
United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (totality-of-the-circumstances and officer experience in reasonable-suspicion analysis)
United States v. Cortez, 449 U.S. 411 (U.S. 1981) (particularized and objective basis requirement for stops)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-the-circumstances approach to informant tips)
Alabama v. White, 496 U.S. 325 (U.S. 1990) (anonymous tips can supply reasonable suspicion if corroborated)
Ex parte Barnette, 624 So.2d 507 (Ala. 1993) (anonymous tip giving easily observable facts, without independent corroboration, insufficient for stop)
Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (fruits of unconstitutional searches/seizures are inadmissible)
Coleman v. City of Dothan, 598 So.2d 873 (Ala. 1992) (test for seizure: whether a reasonable person would believe they were free to leave)