Jaylin Brown v. State of Indiana (mem. dec.), 49A04-1610-CR-2368

On July 4, 2016, during downtown Indianapolis Fourth of July crowd control, an elderly man told police a young Black male in a white T‑shirt and long jean shorts was "showing his gun" on Illinois Street and pointed to Jaylin Brown.
Officers located three young Black males matching the description; one fled when officers approached, Brown and another remained.
Officer Jackson observed Brown reach toward his waistband, placed him in handcuffs, asked about weapons, and then conducted a pat‑down during which he felt and seized a handgun.
Brown was charged with Class A misdemeanor carrying a handgun without a license and proceeded to a bench trial.
At trial the State offered the gun into evidence; Brown moved to suppress claiming the stop and search lacked reasonable suspicion. The trial court admitted the gun and convicted Brown.
The Court of Appeals affirmed, finding the anonymous tip corroborated by officers and Brown’s movements (plus crowd‑safety context) supplied reasonable suspicion for the stop and pat‑down.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Brown)	Held
1) Was the investigatory stop supported by reasonable suspicion?	Anonymous tip gave a specific description and location; officers corroborated by finding matching suspects at the scene, creating reasonable suspicion to stop.	Tip was anonymous and unreliable; corroboration was insufficient to justify a stop.	Yes. The corroborated tip and context (location, clothing, Fourth of July crowd) produced reasonable suspicion to stop.
2) Was the pat‑down for weapons justified?	Officer observed Brown reach toward his waistband, one suspect fled, and officers were policing a high‑risk holiday crowd—facts that reasonably suggested Brown might be armed and dangerous.	Brown did not flee or otherwise change behavior; absence of flight negates reasonable suspicion for a weapons search.	Yes. The combination of the tip, Brown’s movement toward his waistband, a companion’s flight, and crowd‑safety concerns justified a protective pat‑down.

Clark v. State, 994 N.E.2d 252 (Ind. 2013) (standard for appellate review of evidentiary rulings)
Holder v. State, 847 N.E.2d 930 (Ind. 2006) (warrantless searches are per se unreasonable absent an exception)
Terry v. Ohio, 392 U.S. 1 (1968) (officer may stop and briefly detain on reasonable suspicion; may pat down for weapons)
Ybarra v. Illinois, 444 U.S. 85 (1979) (reasonableness of pat‑downs during investigatory stops)
Florida v. J.L., 529 U.S. 266 (2000) (anonymous tips alone rarely justify stop absent corroboration)
Grayson v. State, 52 N.E.3d 24 (Ind. Ct. App. 2016) (anonymous tip corroborated by officer can supply reasonable suspicion)
Williams v. State, 754 N.E.2d 584 (Ind. Ct. App. 2001) (officer may conduct limited search when fear for safety is reasonable)
Brown v. State, 929 N.E.2d 204 (Ind. 2010) (contemporaneous objection suffices to preserve suppression claim)